Information — United States of America v. Joseph Mckeon

Summary

An Information in United States v. Joseph McKeon, also known as Jay McKeon, in the U.S. District Court for the District of New Jersey, filed after he waived prosecution by indictment and charging wire fraud under 18 U.S.C. § 1343 and a monetary transaction count under 18 U.S.C. § 1957. It describes McKeon as the owner of B & T Builders LLC, a purported business in Westfield, New Jersey, and sets out the Paycheck Protection Program's background, including up to approximately $349 billion in forgivable loans under the CARES Act. The Information alleges that McKeon submitted a PPP loan application with falsified supporting documents on behalf of B & T Builders seeking approximately $900,000. It is signed for United States Attorney Philip R. Sellinger.

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Captured: 2026-09-25
Source site: www-justice-gov

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Full text

2023R00923/BDB

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA : Hon.
:
v. : Crim. No. 24-
:
JOSEPH MCKEON, : 18 U.S.C. § 1343
a/k/a “Jay McKeon” : 18 U.S.C. § 1957
:

INFORMATION

The defendant having waived in open court prosecution by Indictment, the

United States Attorney for the District of New Jersey charges:

COUNT ONE
(Wire Fraud)
1. At all times relevant to this Information:

a. Defendant Joseph McKeon, a/k/a “Jay McKeon” (“MCKEON”)

resided in Westfield, New Jersey. MCKEON owned and controlled B & T Builders

LLC, a/k/a “B & T Builder LLC” (“B & T BUILDERS”), a purported business in

Westfield, New Jersey.

b. Company 1 was a loan marketplace platform company

headquartered in Utah, with servers located in Virginia.

c. Lender 1 was a financial services company headquartered in New

York.

d. Title Company 1 was a title company headquartered in Indiana.

e. Bank 1 was a financial institution headquartered in North
Carolina, where B & T BUILDERS held at least one checking account ending in -6485

(“Account 6485”). MCKEON was the sole signatory for Account 6485.

f. Bank 2 was a financial institution headquartered in

Pennsylvania, where MCKEON held at least one checking account ending in -9741

(“Account 9741”) under the name “Joseph McKeon dba Jay McKeon.” MCKEON was

the sole signatory for Account 9741.

g. Bank 3 was a financial institution headquartered in New York,

where MCKEON held at least one checking account ending in -7290 (“Account 7290”)

under the name “First Time Properties LLC.” MCKEON was the sole signatory for

Account 7290.

h. Bank 4 was a financial institution headquartered in Indiana.

The Paycheck Protection Program
i. The Coronavirus Aid, Relief, and Economic Security Act (“CARES

Act”) was a federal law enacted in or around March 2020 designed to provide

emergency financial assistance to Americans suffering economic effects caused by the

COVID-19 pandemic. One source of relief provided by the CARES Act was the

authorization of up to approximately $349 billion in forgivable loans to small

businesses for job retention and certain other expenses, through a program referred

to as the Paycheck Protection Program (“PPP”). In and around April 2020, Congress

authorized over approximately $300 billion in additional PPP funding.

j. To obtain a PPP loan, a qualifying business had to submit a PPP

loan application, which was signed by an authorized representative of the business.

The PPP loan application required the business (through its authorized

2
representative) to acknowledge the program rules and to make certain affirmative

certifications to be eligible to obtain the PPP loan. In the PPP loan application, the

business (through its authorized representative) had to truthfully state, among other

things, its: (a) average monthly payroll expenses; and (b) number of employees. These

figures were used to calculate the amount of money the business was eligible to

receive under the PPP. In addition, a business applying for a PPP loan had to provide

truthful supporting documentation, which could include the business’s tax

information, such as Internal Revenue Service (“IRS”) Forms 941 and Forms 940.

k. A PPP loan application had to be processed by a participating

lender. If a PPP loan application was approved, the participating lender funded the

PPP loan using its own money, which was 100% guaranteed by the United States

Small Business Administration (“SBA”). Data from the application, including

information about the borrower, total amount of the loan, and listed number of

employees was transmitted by the lender to the SBA when processing the loan.

l. PPP money had to be used by the business on certain permissible

expenses—payroll costs, interest on mortgages, rent, and utilities. The PPP allowed

the interest and principal on the PPP loan to be forgiven entirely if the business spent

the money on these expense items within a designated period (usually eight weeks of

receiving the money) and used at least 75% of the PPP money on payroll expenses.

The Scheme to Defraud
2. From in and around February 2021 through in and around February

2022, in Union County, in the District of New Jersey and elsewhere, the defendant,

3
JOSEPH MCKEON,
a/k/a “Jay McKeon,”
did knowingly and intentionally devise and intend to devise a scheme and artifice to

defraud a victim lender, and to obtain money and property by means of materially

false and fraudulent pretenses, representations, and promises, which scheme and

artifice was in substance as set forth below.

Goal of the Scheme to Defraud
3. The goal of the scheme was for MCKEON to enrich himself by

fraudulently obtaining and misusing federal COVID-19 emergency relief money.

Manner and Means of Scheme to Defraud
4. It was part of the scheme that:

a. Over the course of the scheme, MCKEON submitted or caused to

be submitted, on behalf of B & T BUILDERS, two falsified and fraudulent PPP loan

applications through Company 1 to Lender 1 to fraudulently obtain federal COVID-

19 emergency relief money. MCKEON’s fraudulent applications included false

information concerning, among other things, B & T BUILDERS’ average monthly

payroll, gross revenue, and number of employees. It also contained fake supporting

payroll, bank, and tax documents for B & T BUILDERS, including IRS Forms 941

and a Schedule C. To receive the PPP loan, MCKEON completed certain forms by

signing them digitally.

b. In particular, on or about February 23, 2021, MCKEON

submitted or caused to be submitted to Company 1 a falsified PPP loan application

and falsified supporting documents on behalf of B & T BUILDERS seeking a loan for

4
approximately $900,000 (“Application 1”). McKeon listed himself as the sole owner

and primary contact for B & T BUILDERS, and digitally signed Application 1 using

an internet protocol (“IP”) address assigned to MCKEON’s residential address in

Westfield, New Jersey (the “Westfield Residence”) and registered under MCKEON’s

name, phone number, and email address. The Westfield Residence was also B & T

BUILDERS’ business address listed on Application 1, as well as the address for B & T

BUILDERS’ registration with the State of New Jersey Division of Revenue &

Enterprises Services. MCKEON’s submission of Application 1 to Company 1 resulted

in an interstate wire transaction from the Westfield Residence located in New Jersey

through Company 1’s servers located in Virginia.

c. On or about May 7, 2021, MCKEON submitted or caused to be

submitted to Company 1 a second falsified PPP loan application and supporting

documents on behalf B & T BUILDERS that was materially the same as the first

application but included additional falsified supporting documents (“Application 2,”

and together with Application 1, the “Applications”). The Applications falsely stated

that B & T Builders had 60 employees and an average monthly payroll of $360,000.

In fact, B & T BUILDERS had no employees and no payroll.

d. The Applications and their respective supporting documents were

subsequently transmitted by Company 1 to Lender 1 on behalf of MCKEON. On or

about June 17, 2021, MCKEON’s false and fraudulent representations and omissions

caused Lender 1 to disburse approximately $900,000 in loan proceeds into Account

0741 at Bank 1, which was intended for federal COVID-19 emergency relief.

5
e. On or about February 21, 2022, MCKEON submitted or caused to

be submitted a loan forgiveness application to Lender 1 for the approximately

$900,000 in disbursed loan proceeds. On or about November 22, 2022, the SBA

remitted approximately $900,000 in principal and $13,068.49 in interest to Lender 1,

which approved the loan forgiveness application.

f. MCKEON withdrew a significant amount of the loan proceeds as

cash and transferred loan proceeds between and among accounts he controlled,

including from Account 0741 to Account 9741 at Bank 2 and Account 7290 at Bank 3.

He also transferred approximately $315,503.75 in loan proceeds to an account at

Bank 4 owned and controlled by Title Company 1.

Execution of the Scheme to Defraud
5. On or about February 23, 2021, in Union County, in the District of New

Jersey and elsewhere, the defendant,

JOSEPH MCKEON,
a/k/a “Jay McKeon,”
for the purpose of executing and attempting to execute the scheme described above,

did knowingly transmit and cause to be transmitted by means of wire

communications in interstate and foreign commerce certain writings, signs, signals,

pictures, and sounds, namely, the online submission of Application 1 to Company 1

from Westfield, New Jersey through servers in Virginia.

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

6
COUNT TWO
(Money Laundering)
1. The allegations set forth in Paragraphs 1, 3, and 4 of Count One of this

Information are realleged here.

2. On or about July 12, 2022, in Union County, in the District of New

Jersey and elsewhere, the defendant,

JOSEPH MCKEON,
a/k/a “Jay McKeon,”
did knowingly engage and attempt to engage in a monetary transaction by, through,

and to a financial institution, affecting interstate and foreign commerce, in criminally

derived property of a value greater than $10,000, that is, causing a transfer of

approximately $315,503.75 from Account 6485 at Bank 1 to Title Company 1’s

account at Bank 4, such property having been derived from a specified unlawful

activity, that is, wire fraud, contrary to of Title 18, United States Code, Section 1343.

In violation of Title 18, United States Code, Section 1957(a).

7
FORFEITURE ALLEGATION AS TO COUNT ONE

Upon conviction of the offense in violation of Title 18, United States Code,

Section 1343, as charged in Count One of this Information, defendant JOSEPH

MCKEON shall forfeit to the United States, pursuant to Title 18, United States Code,

Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property,

real or personal, which constitutes or is derived from proceeds traceable to the

commission of such offense.

The property to be forfeited includes, but is not limited to, the following assets

(hereafter collectively referred to as the “Specific Property”):

a. Approximately $294,757.04 that was seized on or about August

14, 2024, from Bank 1 account ending in -6485, held in the name of B&T Builders

LLC; and

b. Approximately $36,308.95 that was seized on or about August 14,

2024, from Bank 2 account ending in -9741, held in the name of Joseph McKeon DBA

Jay McKeon.

FORFEITURE ALLEGATION AS TO COUNT TWO

Upon conviction of the offense in violation of Title 18, United States Code,

Section 1957, as charged in Count Two of this Information, defendant JOSEPH

MCKEON shall forfeit to the United States, pursuant to Title 18, United States Code,

Section 982(a)(1), any property, real or personal, involved in such offense, or any

property traceable to such property. The property to be forfeited includes, but is not

limited to, the Specific Property.

8
SUBSTITUTE ASSETS PROVISION
(Applicable to All Forfeiture Allegations)

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

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,

it is the intent of the United States, pursuant to Title 21, United States Code, Section

853(p), as incorporated by Title 28, United States Code, Section 2461(c) and Title 18,

United States Code, Section 982(b), to seek forfeiture of any other property of the

defendant up to the value of the forfeitable property described above.

_____________________________
PHILIP R. SELLINGER
United States Attorney
District of New Jersey

9
CASE NUMBER: 24-
═════════════════════════════════
United States District Court
District of New Jersey
═════════════════════════════════
UNITED STATES OF AMERICA

JOSEPH MCKEON,
a/k/a “Jay McKeon”
═════════════════════════════════
INFORMATION FOR
18 U.S.C. § 1343
18 U.S.C. § 1957
═════════════════════════════════
PHILIP R. SELLINGER
UNITED STATES ATTORNEY
FOR THE DISTRICT OF NEW JERSEY
═════════════════════════════════
BENJAMIN D. BLEIBERG
ASSISTANT U.S. ATTORNEY
NEWARK, NEW JERSEY
973-645-2700
═════════════════════════════════

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