Statement of Facts, United States v. Ibraheem Sabri Samirah (E.D. Va., July 21, 2025)
Summary
A Statement of Facts in United States of America v. Ibraheem Sabri Samirah, Case 1:25-cr-00210-MSN, in the U.S. District Court for the Eastern District of Virginia, Alexandria Division, filed July 21, 2025 as Document 8. The parties agree the government would have proven that from at least in or around May 2020 through at least in or about August 2021 the defendant schemed to defraud Sonabank and the Small Business Administration in connection with a PPP loan of approximately $83,300 for Nova Healthy Smiles PLLC. It states the application falsely claimed four employees and an average monthly payroll of $33,333.32, backed by January and February 2020 payroll records not run until May 2020. It traces salary checks to purported employees whose cash withdrawals were redeposited into the defendant's accounts, and states the scheme generated a loss of approximately $83,000.
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“Statement of Facts, United States v. Ibraheem Sabri Samirah (E.D. Va., July 21, 2025).”
Original at ecf.vaed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/statement-of-facts-usa-v-samirah-dkt-8-e-d-va-a7440a362e/
, SHA-256 d8c079554ae73e8c6bf94f8da94b4466dec89a8b8aef5f2c9f25eb29880d6b2f.Full text
Case 1:25-cr-00210-MSN Document 8 Filed 07/21/25 Page 1 of 10 PageID# 30
FILED
TN OPEN COURT
JUL2 I 'iiy
IN THE UNITED STATES DISTRICTCOURTFOR TH
CLERK, U.S. DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA ALF.XANDRTA, VIRGINIA _
Alexandria Division
UNITED STATES OF AMERICA Case No. l:25-cr-210
V.
IBRAHEEM SABRI SAMIRAH
Defendant.
STATEMENT OF FACTS
The United Slates and the defendant IBRAFIEEM SABRI SAMIRAH (‘‘the defendant” or
“SAMIRAH”) agree that at trial, the United States would have proven the following facts beyond
a reasonable doubt with admissible and credible evidence, all dates listed being on or about the
date indicated:
Background Information
At all relevant times, SAMIRAH resided in Herndon, Virginia, which was located
within the Eastern District of Virginia.
2. On September 30, 2019, Nova Healthy Smiles PLLC (“NHS”) was formed in the
Commonwealth of Virginia, with the principal office address in Herndon, Virginia—the address
for SAMlRAH’s residence at the time. In September 2020, NHS’s address was updated to
SamiralTs new residential address in Herndon, Virginia.
3. Sonabank, later renamed Primis Bank, provided a range of traditional banking
services throughout the United States, including in the Eastern District of Virginia, and was a
financial institution as defined by Title 18, United States Code, Section 20. Sonabank was
Case 1:25-cr-00210-MSN Document 8 Filed 07/21/25 Page 2 of 10 PageID# 31
headquartered in Glen Allen, Virginia.
4. In response to the economic crisis caused by the coronavirus pandemic, in March
2020, Congress made government-guaranteed loans available to qualified small businesses
through the Paycheck Protection Program (“PPP”). The purpose of the PPP loans was to enable
small businesses suffering from the economic downturn to continue to pay salary or wages to their
employees. To qualify for a loan under the PPP, an applicant had to meet certain criteria, including,
among other things, that it was in operation on February 15, 2020, and either had employees for
whom it paid salaries and payroll taxes or paid independent contractors, as reported on an IRS
Form 1099-MISC. Moreover, the amount of the loan that could be approved under the PPP was
typically a function of the applicant’s historic payroll costs. The proceeds of a PPP loan could be
used only for certain specified items, such as payroll costs, costs related to the continuation of
group health care benefits, mortgage interest payments (but not mortgage prepayments or principal
payments), rent payments, utility payments, interest payments on debt obligations that were
incurred before Februaiy 15, 2020, or for refinancing certain specified SBA loans.
5. Small businesses applied for PPP loans with private lenders, including financial
institutions such as Sonabank, that had been approved to participate in the program by the SBA.
The lenders used their own funds to make the PPP loans, but the loans were guaranteed 100 percent
by the SBA.
6. The PPP allowed the interest and principal on the PPP loans to be entirely forgiven
if the business spent the loan proceeds on these expense items within a designated period of time
and used a certain percentage of the PPP loan proceeds on payroll expenses. To receive PPP loan
forgiveness, a qualifying business was required to submit a PPP loan forgiveness application,
which was signed by an authorized representative of the business, to its PPP lender. In the PPP
loan forgiveness application, the borrower (through its authorized representative) had to certify,
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among other things, that it complied with all the requirements in the PPP rules, including the rules
related to eligible uses of PPP loan proceeds, and that the information provided in the application
was true and correct in all material respects. The lenders relied on the accuracy of the information
contained in the PPP forgiveness applications and supporting documents.
7. The SBA received PPP forgiveness applications from PPP lenders through a
cloud-based platform, known as Summit, through an Amazon Web Services GovCloud server
located in Oregon. The SBA transmits the forgiveness payments from the SBA to the PPP lender
through the FMS system to the Treasury. The primary server for FMS is in Sterling, VA.
The Scheme and Artiifce to Defraud and Its Manner and Means
8. From at least in or around May 2020 through at least in or about August 2021, in
the Eastern District of Virginia and elsewhere, the defendant did knowingly, in connection with
the COVlD-19 relief loan he applied for on behalf ofNHS, devise and participate in a scheme and
artifice to defraud Sonabank and the Small Business Administration (“SBA”), and to obtain money
and property from them by means of materially false pretenses, representations, and promises
concerning numbers of employees, quarterly and annual payroll expenses, annual revenues, and
fictitious IRS tax and payroll documents submitted in support of said loan application, all in
violation of Title 18, United States Code, Sections 1343.
9. By at least May 2020, SAMIRAH learned about the PPP loan program. On or
about May 12, 2020, SAMIRAH applied for and was approved for a PPP loan of approximately
$83,300 from Sonabank for NHS.
10. In support of the loan, SAMIRAH submitted a signed “Borrower Application
Form” (SBA Form 2483). On the form, he listed himself as the primary contact for the loan.
SAMIRAH falsely represented that NHS had four employees and an average monthly payroll of
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$33,333.32. SAMIRAH furlher represented that the purpose of the loan was for payroll
lease/mortgage interest, and utilities.
11. On the Borrower Application Form, SAMIRAH agreed to several certifications
by initialing next to them. These certifications were not true.
12. SAMIRAH falsely certified that NHS “had employees for whom it paid salaries
and payroll taxes or paid independent contractors, as reported on Form(s) 1099-MISC.” He further
falsely ceitified that “[t]he funds w[ould] 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.” Finally, SAMIRAH certified “that the information provided in th[e]
application and the information provided in all supporting documents and forms is true and
accurate in all material respects.
13. SAMIRAH submitted several supporting documents with the PPP loan
application, including W-4 forms (Employee’s Withholding Certificate), Payroll Journals, and
Paychex payroll reports for January and February 2020. These documents listed four purported
employees of NHS: SAMIRAH, Employee 1, Employee 2, and Employee 3. The Payroll Journals
and Paychex payroll reports stated that NHS paid each of the purported employees $8,333.33 per
month in January and February 2020 (of which they each received a net monthly paycheck for
$7,695.83), resulting in total salary payments of $33,333.32 for each month. Likewise, SAMIRAH
submitted a Internal Revenue Service (IRS) Form 941 (Employer’s Quarterly Federal Tax Return)
for NHS for 2020, which was signed by SAMIRAH and dated May 11,2020. The IRS Form 941
covered the first quarter of 2020—January to March 2020—and listed four employees and
$66,666.64 paid in wages, tips, and other compensation. SAMIRAH did pay payroll taxes
associated with these wages, tips, and other compensation.
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14. SAMIRAH falsely represented thatNHS paid four employees’ payroll in January
2020 and February 2020, when in truth and fact, NHS did not run payroll journals for those periods
until May 2020. None of the four purported employees received funds from NHS prior to May
2020. NHS issued paychecks for “Salary for January” purportedly dated“l/31/2020” and “Salary
forFebruaiy” purpoitedly dated “2/29/2020,” but NHS did not have its financial account established
until May 7, 2020.
15. After May 14, 2020, checks were written from the NHS business account to
various individuals, as noted in the table below:
Check # Paid To Purported Memo Posted Date Amount
Issued Date
98 Employee 1 2/29/2020 February Salary 5/26/2020 $7,695.83
100 Employee 1 1/31/2020 January Salary 5/26/2020 $7,695.83
1003 Employee 3 1/31/2020 Salary for Januaiy 6/25/2020 $7,695.83
1004 Employee 3 2/29/2020 Salary for February 7/2/2020 $7,695.83
1008 Employee 2 6/16/2020 5/15-6/15 Salary 6/26/2020 $7,695.83
1009 Ibraheem Samirah 6/16/2020 5/15-6/15 Salary 6/25/2020 $7,695.83
1010 Employee 1 10/28/2020 (Blank) 12/10/2020 $6,540.60
1012 IndividuaI-1 6/16/2020 5/15-6/15 Pay/Salary 7/10/2020 $6,259.68
1013 Employee 1 6/16/2020 5/15-6/15 Salary 7/9/2020 $6,259.68
1014 Employee 3 6/16/2020 5/15-6/15 Salary/Pay 12/18/2020 $6,259.68
1016 Individual-2 10/28/2020 (Blank) 12/11/2020 $6,460.96
1017 Employee 3 10/28/2020 (Blank) 12/22/2020 $6,001.06
1018 Ibraheem Samirah 10/28/2020 (Blank) 12/7/2020 $6,001.06
1019 Individual-1 10/28/2020 (Blank) 12/22/2020 $5,549.37
1023 Ibraheem Samirah 1/31/2020 January Salary 6/11/2020 $7,695.83
1024 Employee 2 1/31/2020 January Salary 6/8/2020 $7,695.83
1025 Employee 2 2/29/2020 February Salary 6/8/2020 $7,695.83
1026 Ibraheem Samirah 2/29/2020 February Salary 6/11/2020 $7,695.83
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16. Besides the checks noted in the table above, the only other debits from the NHS
business account at TD Bank were payments to the Paychex payroll service, an ATM withdrawal
for a total of $455, and tax payments to the Internal Revenue Service.
17. Although the above checks appeared to be payments of salary, Employee 1,
Employee 2, and Employee 3 sent money back to SAMIRAH. For example, on May 23, 2020, an
account was opened at PNC Bank in the name of Employee I. On May 26, 2020, two checks for
$7,695.83 each, drawn from the NHS business account at TD Bank, were deposited in Employee
I’s checking account at PNC Bank. One of these checks (check #0100 drawn from the NHS
business account at TD Bank) was dated January 31,2020, and bore the note “Januaiy Salary.
The second check (check #0098 drawn from the NHS business account at TD Bank) was dated
Februaiy' 29, 2020, and bore the note “February Salary.” These two checks posted to the account
on May 26,2020, and comprised the total sum of $ 15,391.66 in Employee I’s PNC Bank account.
18. Also on May 23, 2020, an account was opened at JP Morgan Chase Bank (JPMC)
in the name of Employee 2. On June 8,2020, two checks for $7,695.83 each were deposited to the
account via an ATM in Falls Church, Virginia, which comprised the total amount of $15,391.66
in Employee 2’s JPMC account. One of those checks (check# 1024 drawn from the NHS business
account at TD Bank) was dated January 31,2020, and bore the note “January Salary.” The second
check (check # 1025 drawn from the NHS business account at TD Bank) was dated February 29,
2020, and bore the note “February Salary.
19. Between June 3, 2020, and June 11,2020, there were 16 ATM withdrawals from
Employee 1 ’s PNC Bank account for a total amount withdrawn of $ 11,000 in cash. These ATM
withdrawals all occurred at ATMs in Virginia and Washington, D.C. A review of Employee I’s
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personal bank account at Bank of America shows consistent charges in northeastern Illinois
throughout those same time periods. Between June 10, 2020, and June 11, 2020, there were four
ATM withdrawals from Employee 2’s JPMC account for a total amount withdrawn of
approximately $4,300 in cash. The total amount of cash withdrawn from Employee Ts account
and Employee 2’s account for this time period was $ 15,300. On June 10,2020, a cash deposit was
made to SAMIRAH’s personal TD Bank account in a counter transaction for $9,800; on June 11,
2020, a cash deposit was made to SAMIRAH’s personal Bank of America account in an ATM
transaction for $5,540. The total of these cash deposits to accounts controlled by SAMIRAH was
$15,340.
20. Furthermore, between June 15, 2020, and June 16, 2020, there were six ATM
withdrawals from Employee 1 ’s PNC Bank account for a total amount withdrawn of $4,340. On
June 16, 2020, a cash deposit was made to SAMIRAH’s personal Bank of America account in a
counter transaction for exactly $4,340.
21. On December 10, 2020, check number 1010 was paid from the NHS business
account to Employee 1 ’s Bank of America account for $6,540.60. On December 16,2020, $5,000.00
in cash was withdrawn from Employee I’s Bank of America account in a teller transaction. The
next day, on December 17, $1,500.00 was withdrawn from Employee I’s Bank of American
account via an ATM identified as “CICERO WEST CHICAGO IL.” Two days later, on December
19, a deposit of $6,520.00 was made into Ibraheem SAMIRAH’s personal Bank of America
checking account via an ATM identified as “CICERO WEST CHICAGO IL.” Employee 1 lived
in the Chicago metropolitan area in January and February 2020.
22. On December 18, 2020, a check for $6,259.68 payable to Employee 3 was drawn
from the NHS business account at TD Bank; $4,259.68 was deposited to the Bank of America
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personal checking account of Employee 3, and $2,000.00 was received in cash. This check, #1014
from the NHS business account, bore the note “5/15-6/15 salary/pay.” On December 22, 2020, a
check for $6,001.06 payable to Employee 3 was drawn from the NllS business account at 'I’D
Bank; $4,001.06 was deposited to the Bank of America personal checking account of Employee 3
and $2,000.00 was received in cash. This check was #1017 from the NHS business account. From
December 22 to December 29,2020, $4,260.00 was withdrawn in cash from Employee 3’s account
viaATM. With the two instances of $2,000.00 cash received upon deposit of checks #1014 and
1017, the cash withdrawn from Employee 3’s account totals
$8,260.00. On December 22, 2020, a cash deposit of $1,100 was made via ATM to the NHS
business account. On January 4, 2021, cash deposits of $7,160.00 were made to SAMlRAH’s
personal checking account at TD Bank via five separate ATM transactions at the same location.
The total of these cash deposits to accounts controlled by SAMIRAH was $8,260, the same amount
withdrawn from Employee 3’s account.
23. On or about August 16, 2021, SAMIRAH electronically signed and transmitted
the PPP forgiveness application to Sonabank. Sonabank submitted the PPP forgiveness application
to travel to the SBA’s cloud-based platform, Summit, via a cloud server located in Oregon.
24. SAMIRAH had access to the books and records of NHS. He applied for a PPP
loan for NHS and knew that the numbers of employees, the identities of the employees, the payroll
figures, the revenue figures, and the supporting documents that were provided to the lender and
the U.S. Government in support of the application for a PPP loan were false and that the forgiveness
application for the PPP loan was false.
25. In total, SAMlRAH’s fraud scheme generated a loss of approximately $83,000.
26. This Statement of Facts includes those facts necessary to support the plea
Case 1:25-cr-00210-MSN Document 8 Filed 07/21/25 Page 9 of 10 PageID# 38
agreement between the defendant and the United States. It does not include each and every fact
known to the defendant or to the United States, and it is not intended to be a full enumeration of
all of the facts surrounding the defendant’s case. Furthermore, this statement of facts is an
admission of the defendant that can be used in subsequent court proceedings against him. This
statement of facts does not constitute and are not part of compromise negotiations under Fed. R.
Evid. 410 or any other provision of federal law. As such, the defendant agrees that this statement
of facts should not be excluded or suppressed under Fed. R. Evid. 410, Fed. R. Crim. P. 11 (f), the
Sentencing Guidelines or any other provision of the Constitution or federal law.
27. The actions of the defendant, as recounted above, were in all respects knowing
and deliberate, and were not committed by mistake, accident, or other innocent reason.
Respectfully submitted,
Erik S. Siebert
United States Attorney
Date: June 27. 2025 J
Kathleen E. Robeson '
Assistant United States Attorney
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After consulting with my attorney and pursuant to the plea agreement entered into this day
between the defendant, IBRAHEEM SABRI SAMIRAH, and the United States, I hereby stipulate
that the above Statement of Facts is true and accurate, and that had the matter proceeded to trial,
the United States would have proved the same beyond a reasonable doubt.
IBR/toEM SABRI SAMI
I am Lloyd Liu, defendant’s attorney. I have carefully reviewed the above Statement of
Facts with him. To my knowledge, his decision to stipulate to these facts is an informed and
voluntary one.
\
ABRl SAMIRAH
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