Redacted Indictment — USA v. Hunt (No. 1:25-cr-00046, Dkt. 2, E.D. Mo.)

Summary

An indictment in United States of America v. Shanna Niquia Hunt, Case 1:25-cr-00046-SNLJ, in the United States District Court for the Eastern District of Missouri, filed March 4, 2025 as Doc. #: 2. Count I charges a false statement to a financial institution under 18 U.S.C. § 1014 and Count II charges wire fraud under 18 U.S.C. § 1343. The grand jury charges that on or about April 30, 2021 the defendant submitted a PPP loan application to Benworth Capital Partners, LLC claiming a small business in operation on February 15, 2020, supported by a false 2019 Schedule C. It charges that the lender transferred $19,965.00 to the defendant's bank account. The forfeiture allegations seek a sum of at least $19,956.00; the signature blocks name United States Attorney Sayler A. Fleming and Assistant United States Attorney Tim J. Willis.

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“Redacted Indictment — USA v. Hunt (No. 1:25-cr-00046, Dkt. 2, E.D. Mo.).” Original at ecf.moed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/redacted-indictment-usa-v-hunt-dkt-2-e-d-mo-52ede5baaf/, SHA-256 471ea824ceee778e1b2891ab317e3ebe71c1f672b639743432144f5c5c1d6379.

Full text

Case: 1:25-cr-00046-SNLJ Doc. #: 2 Filed: 03/04/25 Page: 1 of 7 PageID #: 9

FILED

MAR O4 2025
S DIS1RIC1 COLlRT
IN THE UNITED STATES DISTRICT COURT f~"TE°RN DIS1RIC1 Of MO
• CAPf G\Rfl.RDEALl
FOR THE EASTERN DISTRICT OF MISSOURI
SOUTHEASTERN DIVISION

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
vs. ) 1 :25CR00046-SNLJ-ACL
)
SHANNA NIQUIA HUNT, ) Title 18, U.S.C. § 1014.
) Title 18, U.S.C. § 1343.
) Forfeiture allegations.
Defendant. )

INDICTMENT

THE GRAND JURY CHARGES THAT:

At all times material to this Indictment, unless otherwise specified below:

1. Shanna Niquia Hunt, the defendant herein, was a resident of Caruthersville, Pemiscot

County Missouri, within the Southeastern Division of the Eastern District of Missouri.

2. Shanna Hunt did not own or operate a business registered or incorporated within the

State of Missouri which was in operation on February 15, 2020.

The Paycheck Protection Program

3. The United States Small Business Administration ("SBA") is an executive-branch

agency of the United States government that provides supp01i to entrepreneurs and small

businesses. The mission of the SBA is to maintain and strengthen the nation's economy by

enabling the establishment and viability of small businesses and by assisting in economic

recovery after disasters.

4. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act, Pub. L. No.

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Case: 1:25-cr-00046-SNLJ Doc. #: 2 Filed: 03/04/25 Page: 2 of 7 PageID #: 10

116-136, 134 Stat. 281 (2020), is a federal law that was enacted in or around March 2020 to

provide emergency financial assistance to the millions of Americans suffering the economic

impact caused by the COVID-19 pandemic. One source of relief provided for in the CARES Act

was the authorization of forgivable loans to small businesses for job retention and certain other

expenses through the Paycheck Protection Program ("PPP"). The purpose of loans issued under

the PPP was to enable small businesses suffering from the economic downturn to continue to pay

salary, wages and to provide benefits, such as health insurance coverage, to their employees.

5. 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 to acknowledge the program rules and make certain affirmative

ce11ifications to obtain the PPP loan. 1n the PPP loan application (SBA Form 2483), the small

business (tlu·ough its authorized representative) was required to certify: (a) that the small

business was in operation on February 15, 2020; and (b) the average monthly payroll expenses;

and (c) the number of employees. These certifications were used to calculate the amount of

money the small business was eligible to receive under the PPP. In addition, businesses applying

for PPP loans were required to submit documentation supp011ing their payroll expenses.

7. A PPP loan application was then processed by a pai1icipating lender. If a PPP loan

application was approved, the pai1icipating lender funded the loai1 using its own monies, which

were then guaranteed by the SBA. Generally, in the event that the borrower defaulted on a PPP

loan, the SBA would purchase the bonower's debt from the lending financial institution and

assume the responsibility for paying back the loan.

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Case: 1:25-cr-00046-SNLJ Doc. #: 2 Filed: 03/04/25 Page: 3 of 7 PageID #: 11

8. PPP loan funds were required to be used on certain permissible expenses,

including payroll costs, mortgage interest, rent, and utilities for the business. In the PPP loan

application (SBA Fo1m 2483), the borrower must certify that "[a]ll SBA loan proceeds will be

used only for business-related purposes as specified in the loan application and consistent with

the Paycheck Protection Program Rule." In that same application, the borrower must also certify

that "[t]he funds will be used to retain workers and maintain payroll or make mortgage interest

payments, lease payments, and utility payments, as specified under the Paycheck Protection

Program Rule."

9. Under the applicable PPP mles and guidance, the interest and principal on the

PPP loan was eligible for forgiveness if the business spent the loan proceeds on these authorized

expense items within a designated period of time and used a certain p01iion of the loan toward

payroll expenses.

10. Benworth Capital Paiiners, LLC (Benworth), a financial institution headquartered in

Coral Gables, Florida, was a paiiicipating lender and issued PPP loans guarai1teed by the SBA.

Benw01ih processed applications for PPP loai1s that were submitted tlu·ough an internet-based

web p01ial, which affected interstate commerce.

The Scheme to Defraud

COUNTI
False Statement (18 U.S.C. § 1014)

11. Paragraphs 1-10 are realleged and incorporated by reference as if fully set forth herein.

12. On or about April 30, 2021 , in the Southeastern Division of the Eastern District of Missouri

and elsewhere, the defendant, Shaima Hunt, knowingly made a false statement to Benworth Capital

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Case: 1:25-cr-00046-SNLJ Doc. #: 2 Filed: 03/04/25 Page: 4 of 7 PageID #: 12

Partners, LLC, a financial institution, for the purpose of influencing the action of Benworth Capital

Partners, LLC upon an application for a SBA backed PPP loan, in violation of Title 18, United

States Code, Section 1014 and punishable under Title 18, United States Code, Section 1014.

Manner and Means

13. It was a part of the scheme that, on or about April 30, 2021, Shanna Hunt submitted and caused

to be submitted a fraudulent PPP loan application on behalf of Shanna Hunt, which falsely stated:

a) That Shanna Hunt was the owner/ operator of a small business that was in operation in
Missouri on February 15, 2020.

b) That any funds received by way of a PPP loan would be spent on permissible expenses,
such as payroll costs, mortgage interest, rent and utilities for the business which she
claimed.

14. Further, Shanna Hunt knowingly submitted and caused to be submitted certain documents in

support of the fraudulent PPP loan application, including a materially false and fraudulent Internal

Revenue Service (IRS) Schedule C (Form 1040) Profit or Loss From Business form (Schedule C)

for 2019 which falsely represented specified income and expenses.

When in truth and fact, there was no such business and Shanna Hunt had not obtained the
income listed, nor incurred the expenses claimed, and Shanna Hunt did not spend the proceeds of
the loan in a manner consistent with the rules of the program.

COUNT II
Wire Fraud (18 U.S.C. § 1343)

15. Paragraphs 1-10 are realleged and incorporated by reference as if fully set forth herein.

16. On or about April 30, 2021 , in the Southeastern Division of the Eastern District of Missouri

and elsewhere, the defendant, Shanna Hunt voluntarily and intentionally devised or participated in

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Case: 1:25-cr-00046-SNLJ Doc. #: 2 Filed: 03/04/25 Page: 5 of 7 PageID #: 13

a scheme to obtain money by means of material false representations, namely the submission of a

fraudulent PPP loan application, with the intent to defraud, and the defendant used, or caused to

be used an interstate wire communication, that is the electronic submission of a fraudulent loan

application via the internet, for the purpose of obtaining an electronic deposit of funds into a bank

account of Shanna Hunt, in furtherance of the scheme, and the scheme affected Benworth Capital

Partners, LLC, a financial institution, in violation of Title 18 United States Code, Section 1343

and punishable under Title 18, United States Code, Section 1343.

17. It was a part of the scheme that, on or about April 30, 2021, Shanna Hunt submitted and caused

to be submitted a fraudulent PPP loan application on behalf of Shanna Hunt, which falsely stated:

a) That Shanna Hunt was the owner / operator of a small business that was in operation in
Missouri on February 15, 2020.

b) That any funds received by way of a PPP loan would be spent on permissible expenses,
such as payroll costs, mortgage interest, rent and utilities for the business which she
claimed.

18. Further, Shanna Hunt submitted and caused to be submitted certain documents in support of

the fraudulent PPP loan application, including a materially false and fraudulent Internal Revenue

Service (IRS) Schedule C (Form 1040) Profit or Loss From Business form (Schedule C) for 2019

which falsely represented specified income and expenses.

When in truth and fact, there was no such business and Shanna Hunt had not obtained the
income listed, nor incurred the expenses claimed and Shanna Hunt did not spend the proceeds of
the loan in a manner consistent with the rules of the program.
19. As a result of the materially false and fraudulent application for a PPP loan, the lender did

electronically transfer $19,965.00 to a bank account of Shanna Hunt.

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Case: 1:25-cr-00046-SNLJ Doc. #: 2 Filed: 03/04/25 Page: 6 of 7 PageID #: 14

Forfeiture Allegations

The Grand Jury fmther finds by probable cause that:

Pursuant to Title 18, United States Code, Section 982(a)(2)(A) and (a)(3)(F), upon

conviction of an offense in violation of Title 18, United States Code, Section 1014 and/or

Section 1343, as set fo1ih in the Indictment, the defendant shall forfeit to the United States of

America any prope1iy constituting, or derived from, proceeds obtained, directly or indirectly, as

a result of such violation. Subject to forfeiture is a sum of money equal to the total value of the

prope1iy, real or personal, constituting or derived from any proceeds traceable to such violation,

which is at least $19,956.00.

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 transfen-ed or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the comt;
d. has been substantially diminished in value; or
e. has been commingled with other prope1iy which cannot be divided without
difficulty,
the United States of America will be entitled to the forfeiture of substitute prope1iy

pursuant to Title 21, United States Code, Section 853(p).

A TRUE BILL

Foreperson

SAYLER A. FLEMING
United States Attorney

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Case: 1:25-cr-00046-SNLJ Doc. #: 2 Filed: 03/04/25 Page: 7 of 7 PageID #: 15

Tim J. Willis, # 62428MO
Assistant United States Attorney

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