Information — United States v. Salmat Deyji, No. 4:22cr-143 (Dkt. 1, S.D. Ga.)

Summary

This information, filed September 22, 2022 in the Southern District of Georgia, Savannah Division, charges Salmat Deyji with one count of conspiracy under 18 U.S.C. § 371 to commit wire fraud and money laundering, from no later than April 2021 through at least June 2021. It alleges that Deyji created fraudulent PPP applications, including false IRS Schedule C forms that inflated revenue and fabricated businesses, using personal identifying information passed on by coconspirators including Jerrod Bellamy, and was to be paid several thousand dollars per application as a kickback. Lenders outside Georgia deposited more than $250,000 into coconspirators' bank accounts on more than twenty applications Deyji created. The overt acts include an application sent on or about April 4, 2021 and a $2,000 wire transfer from Bellamy on or about April 26, 2021.

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Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 1 of 5

FILED
John E. Triplett, Clerk of Court

UNITED STATES DISTRICT COURT
United States District Court

SOUTHERN DISTRICT OF GEORGIA
By jburrell at 1:07 pm, Sep 22, 2022

SAVANNAH DIVISION

UNITED STATES OF AMERICA ) INFORMATION NO. 4:22cr-143
)
v. ) 18 U.S.C. § 371
) Conspiracy
SALMAT DEYJI )

THE UNITED STATES ATTORNEY CHARGES THAT:

COUNT ONE
Conspiracy
18 U.S.C. § 371

1. Beginning no later than April 2021 and continuing through at least June

2021, within the Southern District of Georgia, Northern District of Georgia, and

Western District of Texas, and elsewhere, the defendant,

SALMAT DEYJI,

did knowingly and willfully combine, conspire, confederate, and agree with at least

one other person to:

a. devise or intend to devise a scheme or artifice to defraud, and for

obtaining money or property by means of false or fraudulent pretenses,

representations, or promises, and to transmit or cause to be transmitted by wire

communication in interstate commerce any writings, signs, signals, pictures, or

sounds for the purpose of executing such scheme or artifice, in violation of 18 U.S.C.

§ 1343, and

b. commit money laundering, that is to knowingly conduct and

attempt to conduct a financial transaction affecting interstate and foreign commerce,
Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 2 of 5

which involved the proceeds of a specified unlawful activity, that is wire fraud, with

the intent to promote the carrying on of wire fraud, and that while conducting and

attempting to conduct such financial transaction knew that the property involved in

the financial transaction represented the proceeds of some form of unlawful activity,

in violation of 18 U.S.C. § 1956, the conspiracy to commit such offenses being in

violation of 18 U.S.C. § 371.

2. The object of the conspiracy was for Defendant and her coconspirators

to unjustly enrich themselves by making false PPP applications to lenders, to

unlawfully induce the lenders to disburse SBA-backed loans to coconspirators in

amounts to which they were not entitled, and who, in turn, would pay a portion of the

ill-gotten funds to Defendant as a kickback through financial transactions.

3. It was a part of the conspiracy that Defendant and coconspirators,

including Jerrod Bellamy, would perform the following:

a. Defendant and coconspirators utilized cellular devices and the

internet to create fraudulent PPP applications. Some coconspirators would provide

Bellamy with their personal identifying information (PII) to create a false loan.

Bellamy would, in turn, send the PII to Defendant, who would then use the internet

to create fraudulent PPP applications. After a PPP application was approved by a

lender, the conspirators would electronically receive, sign, and submit loan

documents to the lender.

b. To disguise the falsity of such applications, Defendant would

utilize a computer and the internet to create false IRS Schedule C forms. The

2
Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 3 of 5

Schedule C forms were submitted as part of the application to dupe lenders. Such

forms inflated revenue and fabricated the existence of businesses.

c. On other occasions, Defendant would directly obtain the PII of

those seeking loans and create false and fraudulent applications on their behalf.

d. In exchange for Defendant completing a fraudulent PPP

application, applicants and coconspirators agreed to pay Defendant several thousand

dollars per PPP application. Once coconspirators received the PPP funds derived

from the false application, they would transmit a kickback to Defendant through

bank transfers to her accounts. Such transmissions were financial transactions

representing the proceeds of a specified unlawful activity, namely wire fraud. In

2021, Defendant received tens of thousands of dollars in her Navy Federal Credit

Union bank account from the fraudulent scheme.

4. On or about April 4, 2021, in the Southern District of Georgia and

elsewhere, Defendant, aided and abetted by others, for the purpose of executing the

scheme and artifice described above, and attempting to do so, caused to be

transmitted in interstate commerce, by means of wire communication, certain signs,

signals, and sounds: that is, on or about April 4, 2021, Defendant transmitted an

electronic PPP application from the Southern District of Georgia to a lender outside

the State of Georgia seeking funds, knowing that such application contained false

information.

5. In reliance on false representations made in more than twenty PPP

applications created by Defendant, lenders headquartered outside the State of

3
Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 4 of 5

Georgia, by means of wire communication, deposited more than $250,000 into

coconspirators’ bank accounts resulting from this scheme.

6. On or about April 26, 2021, in the Southern District of Georgia and

elsewhere, Bellamy conducted a financial transaction affecting interstate and foreign

commerce, which involved the proceeds of wire fraud. As part of the conspiracy,

Defendant received a wire transfer of $2,000 from Bellamy on that date, knowing that

the money was obtained from the proceed of a fraudulently obtained PPP application,

and with the intent to promote the carrying on of the wire fraud conspiracy in which

they and others were engaged.

All done in violation of Title 18, United States Code, Section 371.

4
Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 5 of 5

David H. Estes
United States Attorney Assistant United States Attorney
*Lead Counsel

Patricia G. Rhodes
Assistant United States Attorney
Chief, Criminal Division

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