Plea Agreement — United States v. Bock et al. (Feeding Our Future) (Dkt. 882, D. Minn.)

Summary

In this plea agreement filed 05/14/26 in the District of Minnesota, Abdirahman Mohamud Ahmed, also known as "Chef Abcos," agrees to plead guilty to Count 57 of the Indictment, money laundering in violation of 18 U.S.C. § 1957. The factual basis states that Ahmed's business partners and co-defendants enrolled Safari Restaurant under Feeding Our Future's sponsorship and claimed 3,900,285 meals from April 2020 to April 2021, for which the restaurant was reimbursed $12,123,857. It says Ahmed, then living in Ohio, did not personally prepare the claims but was deliberately blind and kept a share of the profits totaling over $2.4 million. On or about August 30, 2021, Ahmed, Salim Said and Abdulkadir Salah paid approximately $2.4 million toward a commercial building in Columbus, Ohio. Ahmed agrees to owe restitution of $2,434,389, jointly and severally.

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CASE 0:22-cr-00223-NEB-DTS Doc. 882 _ Filed 05/14/26 Pagei1of13

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Criminal No, 22-223 (NEB/DTS)

UNITED STATES OF AMERICA,

. Plaintiff, PLEA AGREEMENT AND

y SENTENCING STIPULATIONS

14, ABDIRAHMAN MOHAMUD AHMED,
also known as “Chef Abcos,”

Defendant.

The United States of America and the defendant, Abdirahman Mohamud
Ahmed, agree to resolve this case on the terms and conditions that follow. This plea
agreement binds only the defendant and the United States Attorney’s Office for the
District of Minnesota (hereinafter “the United States” or “the Government’), This
agreement does not bind any other United States Attorney’s Office or any other
federal or state agency.

1. Charges. The defendant agrees to plead guilty to Count 57 of the
Indictment, which charges the defendant with money laundering, in violation of Title
18, United States Code, Section 1957, The defendant fully understands the nature
and elements of the crimes with which he has been charged. Upon imposition of
sentence, the United States agrees to move to dismiss the remaining charges against
the defendant contained in the Indictment,

2. Factual Basis. The defendant is pleading guilty because he is in fact

guilty of Count 57 of the Indictment. In pleading guilty, the defendant admits the
following facts, and that those facts establish his guilt beyond a reasonable doubt and
constitute relevant conduct pursuant to the United States Sentencing Guidelines:

The Food and Nutrition Service, an agency of the United States Department
of Agriculture (USDA), funds the Federal Child Nutrition Program, a program
designed to provide free meals to children in need. The Minnesota Department of
Education (MDE) administers the Federal Child Nutrition Program in Minnesota.

Meals funded by the Federal Child Nutrition Program in Minnesota are served
at “sites.” Each site participating in the Federal Child Nutrition Program must be
sponsored by an organization that is authorized to participate in the Federal Child
Nutrition Program. Sponsors submit reimbursement claims to MDE on behalf of sites
under their sponsorship. The USDA provides federal reimbursement funds to MDE
on a per-meal basis. MDE provides the federal funds to the sponsoring agency, which
in turn pays the reimbursement funds to the sites under its sponsorship,

From in or about April 2020 through in or about January 2022, defendant
Abdirahman Mohamud Ahmed’s business partner's and co-defendants participated in
a scheme to defraud the Federal Child Nutrition Program. As part of the scheme, Mr,
Ahmed's business partners enrolled the Minneapolis-based restaurant they co-owned
with My, Ahmed, Safari Restaurant, in the Federal Child Nutrition Program under
the sponsorship of Feeding Our Future. Immediately upon enrolling Safari
Restaurant in the Federal Child Nutrition Program through Feeding Our Future, Mr, |
Ahmed’s business partners and co-defendants began submitting fraudulent meal

veimbursement claims alleging to be serving meals at Safari Restaurant to thousands
CASE 0:22-cr-00223-NEB-DTS Doc. 882 Filed 05/14/26 Page 3 of 13

of children every day, 7 days a week. For the 12-month period from April 2020 to
April 2021, Mr. Ahmed’'s business partners and co-defendants claimed to serve
3,900,285 meals to children, for which Safari Restaurant was reimbursed
$12,123,857 in Federal Child Nutrition Program funds. The number of meals
allegedly served to children at Safari Restaurant was grossly inflated and only a
small fraction of Federal Child Nutrition Program funds Safari Restaurant received
was used to purchase food.

Because Mr. Ahmed: was living in Ohio at the time, he did not directly or
personally participate in preparing or submitting fraudulent meal reimbursement
claims. He nonetheless believed there was a high probability that his business
partners and co-defendants were submitting fraudulent meal reimbursement claims
and deliberately was blind to what would otherwise have been obvious to him. This
included that Safari Restaurant could not have legitimately made the level of profit
. that it did from the Federal Child Nutrition Program. My. Ahmed deliberately did not .
inquire of his business partnev's and co-defendants about the source and legitimacy
of the profits, nor did he contact authorities and express his concerns. He instead
simply kept his share of the profits, which totaled over $2.4 million.

Mr, Ahmed used the criminal proceeds he received from Safari Restaurant to
engage in monetary transactions by, through, or to a financial institution, affecting
interstate commerce, and involving more than $10,000, including the transaction
alleged in Count 57 of the Indictment, That is, on or about August 30, 2021, Mr.

Ahmed and his business partners and co-defendants Salim Said and Abdulkadir
CASE 0:22-cr-00223-NEB-DTS Doc. 882 _ Filed 05/14/26 Page4of13

Salah paid approximately $2.4 million towards the purchase of a commercial building
located at 2345 Seltzer Road, in Columbus, Ohio—such property having been derived
from specified unlawful activities, namely, wire fraud, in violation of Title 18, United

States Code, Section 1343.

3. Waiver of Pretrial Motions. The defendant understands and agrees

that he has certain rights to file pre-trial motions in this case. As part of the plea
agreement, and based upon concessions of the United States within this plea
agreement, the defendant knowingly, willingly, and voluntarily gives up the right to
file any pre-trial motions in this case, The defendant agrees that, by pleading guilty,
he is withdrawing any motions previously filed.

4, Waiver of Constitutional Trial Rights, The defendant understands

that he has the right to go to trial. At trial, the defendant would be presumed
innocent, have the right to trial by jury or, with the consent of the United States and
of the Court, to trial by the Court, the vight to the assistance of counsel, the right to
confront and cross-examine adverse witnesses, the right to subpoena witnesses to
testify for the defense, the right to testify and present evidence, and the right to be
protected from compelled self-incrimination. The defendant understands that he has
the right to an attorney at every stage of these proceedings and, if necessary, one will
be appointed to represent him. The defendant understands that he has the right to
persist in a plea of not guilty and, if he does so, he would have the right to a public
and speedy trial. By pleading guilty, the defendant knowingly, willingly, and

voluntarily waives each of these trial vights, except the right to counsel. The
CASE 0:22-cr-00223-NEB-DTS Doc. 882 _ Filed 05/14/26 Page5of13

defendant understands that a guilty plea is a complete and final admission of guilt
and, if the Court accepts the guilty plea, the Court will adjudge the defendant guilty

without a trial.

5, Additional Consequences. The defendant understands that as a

result of his conviction, he could experience additional consequences, such as the loss
of the vight to carry firearms, the right to vote, and the right to hold public office.

6. Statutory Penalties. The parties agree that money laundering, as

charged in Count 57 of the Indictment, carries statutory penalties of;

a. a maximum of 10 years in prison;

b. a supervised release term of up to 3 years;

¢. a fine of up to $250,000, or twice the amount of the criminally
derived property involved in the transaction;

da, restitution as agreed to by the parties in this agreement; and

e, a mandatory special assessment of $100.

7. Revocation of Supervised Release. The defendant understands that
if he were to violate any supervised release condition while on supervised release, the
Court could revoke his supervised release, and the defendant could be sentenced to
an additional term of imprisonment up to the statutory maximum set forth in 18
U.S.C. § 3583(e)(8). See U.S.S.G. §§ 7B1.4, 7B1.5. The defendant also understands
that as part of any revocation, the Court may include a requirement that he be placed

on an additional term of supervised release after imprisonment, as set forth in 18

“U.S.C. § 8583(h).
CASE 0:22-cr-00223-NEB-DTS Doc. 882 _ Filed 05/14/26 Page6of13

8. Guidelines Calculations, The parties acknowledge that the defendant

will be sentenced in accordance with 18 U.S.C. § 36551, et seq. Nothing in this plea

agreement should be construed to limit the parties from presenting any and all

relevant evidence to the Court at sentencing. The parties also acknowledge that the

Court will consider the United States Sentencing Guidelines in determining the

appropriate sentence and stipulate to the following guideline calculations:

a,

~ Base Offense Level. The parties agree that the base offense level

for money laundering is 24 because the amount laundered was
more than $1,500,000 but less than $8,500,000, U.S.5.G. §
251,1(a)(2) and 2B1.1(b)(1)(H).

Specific Offense Characteristics, The parties agree that the
offense level should be increased by 1 level because the
defendant's charge of conviction is 18 U.S.C. § 1957. U.S.S.G.

§ 2S1.1(b)(2)(A).

Chapter 3 Adjustments. The parties agree that the defendant's
offense level should be reduced 4 levels, pursuant to U.S.S.G, §
8B1.2(a), because he was a minimal participant in any criminal
activity. The parties otherwise agree that, other than credit. for
acceptance of responsibility, no Chapter 3 adjustments apply.

Acceptance of Responsibility. The government agrees to
recommend that the defendant receive a 2-level reduction for
acceptance of responsibility pursuant to U.S.8.G, § 38E1.1(a). As
the defendant has timely notified the government of his intention
to enter a plea of guilty, the government agrees to recommend
that the defendant yeceive an additional 1-level reduction
pursuant to U.S.S.G. § 8E1.1(b). Whether these reductions will be
imposed shall be determined by the Court in its discretion.
However, the defendant understands and agrees that the
government's recommendations are conditioned upon the
following: (1) the defendant testifies truthfully during the change
of plea and sentencing hearings; (2) the defendant provides full,
complete and truthful information to the United States Probation
Office in the pre-sentence investigation; and (8) the defendant
engages in no conduct inconsistent with acceptance of
responsibility before the time of sentencing, including frivolously
denying facts in the Presentence Report. Nothing in this

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CASE 0:22-cr-00223-NEB-DTS Doc. 882 _ Filed 05/14/26 Page/7of13

agreement limits the right of the government, pursuant to
U.S.S.G. § 3E1.1 and/or § 8C1.1 to seek denial of a reduction for
acceptance of responsibility or an enhancement for obstruction of
justice should the defendant engage in any conduct inconsistent
with acceptance of responsibility, including moving to withdraw
his guilty plea after it is entered.

Q, Criminal History Category, The parties believe that, at the time
of sentencing, the defendant will fall into Criminal History
Category I. U.S.S.G. § 4A1.1. This does not constitute a
stipulation, but a belief based on an assessment of the
information currently known. The defendant's actyal criminal
history and related status will be determined by the Court based
on the information presented in the Presentence Report and by
the parties at the time of sentencing. The defendant understands
that if the presentence investigation reveals any prior adult or
juvenile sentence that should be included within his criminal
history under the U.S. Sentencing Guidelines, the defendant will
be sentenced based on his true criminal history category, and he
will not be permitted to withdraw from this Plea Agreement.

U.S.S.G, § 4A1,1.

f. Zero-Point Offender Adjustment. Assuming the defendant has
zero criminal-history points and no disqualifying conduct, the
parties agree the defendant qualifies for a 2-level adjustment

under U.S.S.G. § 4C1.1.

g. Guidelines Range. If the adjusted offense level is 16 and the
criminal history category is I, the Sentencing Guidelines range is
21 to 27 months of imprisonment.

h. Fine Range. If the adjusted offense level is 16, the Sentencing
Guidelines fine range is $10,000 to $95,000. U.S.S.G.

§ 5E1.2(c)(8).
9. Discretion of the Court. The foregoing stipulations are binding on the
parties, but do not bind the Court. The parties understand that the Sentencing
Guidelines are advisory and their application is a matter that falls solely within the

Court’s discretion. The Court may make its own determination regarding the

applicable guideline factors and the applicable criminal-history category. The Court
CASE 0:22-cr-00223-NEB-DTS Doc. 882 Filed 05/14/26 Page 8of13

may also depart from the applicable Guidelines. If the Court determines that the
applicable guideline calculations or the defendant’s criminal history category are
different from that stated above, such a determination shall not provide a basis for
the parties to withdraw from this agreement, and the defendant will be sentenced

pursuant to the Court’s determinations,

10. Agreements as to Sentencing Recommendation. At the time of
sentencing, the government agrees to recommend that the defendant receive a non-
custodial sentence. The parties reserve the right to make motions for departures from
the applicable Guidelines range pursuant to 18 U.S.C. § 3553(a), to oppose any such
motion made by the opposing party, and to argue for a sentence outside the applicable
Guidelines range. If the Court does not accept the sentencing recommendation of the
parties, the defendant will have no right to withdraw his guilty plea.

11. Special Assessment. The Sentencing Guidelines require payment of a

special assessment in the amount of $100 for each felony count of which the defendant
is convicted. U.S.S.G. § 5£1.8. The defendant agrees that the special assessment is

due and payable at the time of sentencing.

12. Restitution Agreement. The defendant understands and agrees that

the Mandatory Victim Restitution Act, 18 U.S.C, § 3663A, applies and that the Court
is required to order the defendant to make restitution to the victims of his crime. The
defendant understands and agrees the Court may order the defendant to make

restitution to any victim of the scheme regardless of whether the victim was named
CASE 0:22-cr-00223-NEB-DTS Doc. 882 _ Filed 05/14/26 Page9of13

in the Indictment. The defendant agrees that he owes restitution in the amount of
$2,434,389, jointly and severally with all other co-defendants in the Indictment.

13. Disclosure of Assets. The defendant will fully and completely disclose

to the United States Attorney’s Office the existence and location of any assets in
which the Defendant has any right, title, or interest, or over which the defendant
exercises control, directly or indirectly, including those assets held by a spouse,
nominee oy other third party, or any business owned or controlled by the defendant.
The defendant agrees to assist the United States in identifying, locating, returning,
and transferring assets for use in payment of fines and/or forfeiture ordered by the
‘Court. The Defendant agrees to complete a financial statement within two weeks of
the entry of his guilty plea. The defendant further agrees to execute any releases that
may be necessary for the United States to obtain information concerning the
defendant’s assets and expressly authorizes the United States to obtain a credit
report on the defendant to evaluate his ability to satisfy financial obligations imposed
by the Court. If requested by the United States, the defendant agrees to submit to
one or more asset interviews or depositions under oath.

14, Forfeiture, The defendant agrees to forfeit to the United States,
pursuant to 18 U.S.C. § 982(a)(1), any property, real or personal, involved in a
transaction or attempted transaction in violation of Title 18, United States Code,
Section 1957, and any property traceable to such property, as charged in Count 57 of

the Indictment. The property subject to forfeiture includes, but is not limited to, the
CASE 0:22-cr-00223-NEB-DTS Doc. 882 Filed 05/14/26 Page10of13

real property located at 2435 Stelzer Road, Columbus, Ohio, or any proceeds traceable
to the sale of that property,

The parties acknowledge that the United States has completed the
administrative forfeiture of $456,965.90 in funds from account number xxxxxx6863
held in the name of Abdivahman Ahmed at Fifth Third Bank, Cincinnati, Ohio. The
defendant also agrees that the 2018 Lexus RX 350, VIN 2T2BZMCA1JC153144, is
subject to forfeiture. He agrees that vehicle may be forfeited through civil judicial or
non-judicial (administrative) forfeiture proceedings, and he agrees to complete a
waiver of timely notice form, abandonment, or any such other document as may be
required to effect the administrative forfeiture of that vehicle. Defendant specifically
waives any right to receive notice of the forfeiture of the vehicle under 18 U,S.C. § 983
or to otherwise contest, directly or indirectly, its forfeiture.

The United States reserves the right to seek a money judgment forfeiture,
forfeiture of directly forfeitable assets, and forfeiture of substitute assets.

The defendant waives all statutory and constitutional defenses to the forfeiture
of the assets described above and waives any right to contest or challenge (including
direct appeal, habeas corpus, or any other means) such forfeiture, directly or through
any company he owns or controls, on any grounds, To the extent the defendant has
sought remission or otherwise challenged the forfeiture of the above-described

property, the defendant withdraws any such challenges

15. Waivers of Appeal and Collateral Attack. The parties hereby waive

the right to appeal any non-jurisdictional issues, This appeal waiver includes, but is

10
CASE 0:22-cr-00223-NEB-DTS Doc. 882 Filed 05/14/26 Page11of13

not limited to: the issue of the defendant's guilt or innocence, any issues relating to
the negotiation, taking or acceptance of the guilty plea, the sentence imposed or any
issues that relate to the calculation of the Guidelines range, the supervised-release
term and conditions imposed, any restitution obligations, and the constitutionality of
the statutes to which the defendant is pleading guilty. The parties agree, however,
that excluded from this waiver is an appeal by defendant of the substantive
reasonableness of a term of imprisonment above the top of the Guidelines range, and
an appeal by the government of the substantive reasonableness of a term of
imprisonment below the bottom of the Guidelines range.

The defendant also waives the right to collaterally attack his conviction and
sentence under 28 U.S.C. § 2255 except based upon a claim of ineffective assistance
of counsel. This collateral-review waiver does not operate to waive a collateral
challenge under 28 U.S.C. § 2255 based on new legal principles enunciated in
Supreme Court case law decided after the date of this Plea Agreement that are both
substantive and have retroactive effect. For purposes of this provision, legal .
principles that are substantive and retroactive ave those that narrow the reach of the
offense of conviction and vender the defendant's conduct non-criminal or that render
the sentence imposed illegal.

The defendant has discussed these rights with the defendant’s attorney. The
defendant understands the rights being waived, and the defendant waives these

rights knowingly, intelligently, and voluntarily.
CASE 0:22-cr-00223-NEB-DTS Doc. 882 Filed 05/14/26 Page 12 of13

16. FOIA Requests. The defendant waives all rights to obtain, directly or

through others, information about the investigation and prosecution of this case
under the Freedom of Information Act and the Privacy Act of 1974, 5 U.S.C. §§.552,

552A.

17. Complete Agreement. This, along with any agreement signed by the

parties before entry of plea, is the entire agreement and understanding between the
United States and the defendant. By signing this plea agreement, the defendant
acknowledges: (a) that the defendant has read the entire agreement and has reviewed
every part of it with the defendant's counsel; (b) that the defendant fully understands
this plea agreement; (c) that no promises, agreements, understandings, or conditions
have been made or entered into in connection with his decision to plead guilty, except
those set forth in this plea agreement; (d) that the defendant is satisfied with the
legal services and representation provided by defense counsel in connection with this
plea agreement and matters related to it; (e) that the defendant has entered into this
plea agreement freely, voluntarily, and knowingly; and (f) that the defendant's
decision to plead guilty in accord with the terms and conditions of this plea agreement

is made of the defendant’s own free will.

Dated: . e DANIEL N. ROSEN
S- ) 4 VA = United States Attorney

BY: U
REBECCA E, KLINE

MATTHEW C. MURPHY
Assistant United States Attorneys

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