AO 9 1 (Rev 08/(y)) Crlmlnal Complalnl

U NITED STATES D ISTRICT COURT

for the

Stputhern District of Florida

United States of America

V .

Damion Mckenzie, case xo. g p -p' yzy

f lehmdanltsl

CRIM INAL COM PLAINT

1. the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the datets) of M4y 1 5p)ply.;.,.,,;..lgp in the county of Broward in the

%p.p!h.:rn-..---... District of Florida . .. .....,.,..... . the defendantts) violaîed:

Code u%c#(?z?

18 U.S.C. jj 1M 3 and 2

18 U.S.C. sâ 1M4 and 2

18 U.S.C. 5 1349

(Lllfkttse Dtd-î.cr/pl&?p?

W ire Fraud

Bank Fraud

Conspiracy/Attem pt to Comm it W ire and Bank Fraud

This criminal complaint is based on these facts:

SEE AU ACHED AFFIDAVIT.

W Continued on the attached sheet.

4

A

('*f.),??/.#(./&,(fz'?f %' signulure

MichA#I,.,,B,. vnivqgna, Spr iyl Ag#pt, lR, sr4l

Printed name zzat/ title

Attested îo by the applicant in accordafwc with the requiremenls of Fed. R. Crim. P. 4.l by telephone.

Date: . 1 X O

Judge 's x/kaalt/rf?

City and state: - .. . . . - ...F. t, Lpvd-qrdple, Flvri.. Hpn., qytxuliç.k--y-ulj.pp!z u,,s., , Mp.gi.qtrpte Jpdg-.. .. itrlntett z'u?rac f,,,k titli.t '''

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AFFID AVIT

1, M ichael Benivegna, being Grst duly sw orn, hereby depose and state as follows:

IN TRO DU C H O N A ND A GEN T BA CK G RO UN D

I m ake this Affidavit in support of a crim inal com plaint charging DA M ION

MCKENZIE ('VM CKENZIE'' or çiDefendant''), with wire fraud, bank fraud, attempt and

conspiracy to commit wire fraud and bank fraud, in violation of 18 U.S.C. jj 1343, 1344, 1349,

and 2, from on or about M ay 15, 2020 to at least on or about July 2, 2020, in the Southern District

of Florida, and elsewhere (the gt-rarget Offenses'').

2. Defendant has participated in a scheme to obtain by fraud millions of dollars in

forgivable loans through the Paycheck Protection Program (iiPPP'') and other government

programs, conspiring with a person now cooperating with the investigation (SCCHS 29') and others.

Defendant sought a fraudulent PPP loan for his own company, Five Plus lnvestm ent Group LLC

(ttFive PIus'*), with CHS 2 providing falsified documentsand submitting the application on

Defendant's behalf. Defendant also conspired to subm it a num ber of additional fraudulent PPP

Ioan applications for other com panies by recruiting other confederate loan applicants, in order to

receive kickbacks from those confedem tes. To intlate the size of these PPP loans, and the

corresponding kickbacks, the conspirators relied on a variety of false statem ents, including by

subm itting falsified bank statements and payroll tax forms. For example, the conspirators used

nearly identical versions of the same fabricated bank statements, recycled in the PPP applications

for multiple companies with m inor changes.

The conspirators in the schem e planned or prepared at Ieast 90 fraudulent

applicationss m ost of which were subm itted. Based on the evidence investigators have reviewed

to datee CH S 2, Defendant, and their co-conspirators applied for PPP loans that are together worth

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more than $24 million dollars, with at least approximately 42 of those loans approved and funded

for a total of-approximately $1 7.4 m illion. Certain of those loan recipients then wired a kickback

of varying amounts, often approximately 25% of the fkaudulent loan proceeds, to an account

controlled by CH S 2.

4. I am a Special Agent with the United States Department of The Treasury, lnternal

Revenue Service, Criminal lnvestigation C$lRS-C1'') and have been employed in this capacity since

October 2016. l am presently assir ed to the M iami Field Oftk e. M y duties as a Special A gent

include the investigation of possible criminal violations of the lnternal Revenue Code (Title 26 of

the United States Code), the Bank Secrecy Act (Title 31 of the United States Code), and the Money

Laundering Statutes (Title 1 8 of the United States Code). l gaduated from the Criminal

Investigator Training Program at the Federal Law Enforcem ent Training Center in A pril 20l 7 and

the Special Agent Investigative Techniques program at the N ational Crim inal Investigation

Training Academy in July 20 1 7. In these two programs, 1 studied a variety of law enforcement

tactics and criminal investigator techniques relating to tax and financial crimes. Since becoming

an IRS-CI Special Agent, l have personally investigated and assisted in investigations relating to

the lnternal Revenue Law s and financial crim es. Recently, I have been assigned to w ork with the

U.S. Departm ent of Justice and other law enforcem ent partners, including the Federal Bureau of

lnvestigation and the Sm all Business A dm inistration Offk e of Inspector Genem l, to investigate

possible fraud associated w ith the stim ulus and econom ic assistance program s created by the

federal government in response to the COVID- 19 program .

The facts in this A ffqdavit com e from m y personal observations, my training and

experience, and information obtained from other m embers of law enforcem ent and from witnesses.

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This Affidavit is intended to show m erely that there is sufficient probable cause and does not set

forth all of m y know ledge about this m atter. 1

PR O BA BLE CAUSE

The Jk pc/leck Protection Pros am

6. The Coronavirus Aid, Relief, and Economic Security CVCARES'') Act is a fedeml

law enacted in or around M arch 2020 and designed to provide emergency fmancial assistance to

the m illions of A mericans who are suffering the economic effects caused by the COV1D-19

pandemic. One source of relief provided by the CARES Act was the authorization of up to $349

billion in forgivable Ioans to snzall businesses forjob retention and certain other expenses, through

a program referred to as the PPP. In or around April 2020, Congress authorized over $300 billion

in additional PPP funding.

ln order to obtain a PPP loan, a qtlalifying business m ust subm it a PPP loan

application, which is signed by an authorized representative of the business. The PPP loan

application requires the business (through its authorized representative) to acknowledge the

program rules and make certain affirmative certitkations in order to be eligible to obtain the PPP

loan. In the PPP loan application, the small business (through its authorized representative) must

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

n ese figures are used to calculate the amount of money the sm all business is eligible to receive

under the PPP. ln addition, businesses applying for a PPP Ioan m ust provide docum entation

showing their payroll expenses.

1 The conduct and charges described in this Affidavit are part of a larger investigation that

is being conducted in this D istrict and elsewhere. As a result, not all num bered sources and

anonymous individuals and entities are described in every filing. I have included in this Affidavit

only those individuals and entities 1 have deemed necessary to explain the particular facts set forth

here.

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A PPP loan application m ust be processed by a participating lender. lf a PPP loan

application is approved, the padicipating lender funds the PPP loan using its own monies, which

are 1 00% guaranteed by the Small Business Administration (éçSBA''). Data from the application,

including inform ation about the borrower, the total am ount of the loan, and the listed num ber of

employees, is transm itted by the lender to the SBA in the course of processing the Ioan.

9. PPP loan proceeds must be used by the business on certain permissible expenses

payroll costs, interest on m ortgages. rent, and utilities. The PPP allows the interest and principal

on the PPP loan to be entirely forgiven if the business spends the loan proceeds on these expense

item s w ithin a designated period of tim e after receiving the proceeds and uses a certain am ount of

the PPP loan proceeds on payroll expenses.

The Scheme to Obtain Fraudulent PPP L oans

10. On or about May l3, 2020, Phillip J. Augtlstin CsAugustin'') and CHS 2 worked

together to subm it a fraudulent PPP loan application on behalf of a com pany ow ned by A ugustin.

Augustin submitted a PPP loan of $84,515 to a federally insured bank (hereinafter çsBank 3''),

through a third-party company processor (hereinafter ''Bank Processor 1',).2 The application

included bank statements that are clear forgeries, and CHS 2 has admitted that the application was

based on docum ents that he falsified for Augustin.3

2 A1l banks referenced in this Affidavit are insured by the Federal Deposit lnsurance

Corporation.

On June 25, 2020, investigators arrested CHS 2 and another jerson now cooperating with

the investigation (ûECHS 39') and executed search warrants at their resldences. Following his arrest,

CH S 2 chose to cooperate w ith the investigation in the hope of obtaining favorable consideration

in connection w ith his pending charges. CH S 2 was interviewed on that day, and has continued to

cooperate w ith the investigation after obtaining counsel. M ost of his statements related herein

have been corroborated by records obtained from third parties or recovered from his electronic

devices.

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Follow ing the success of that initial fraudulent PPP application, Augustin and CHS

2 began to work on obtaining m ore and larger PPP loans fbr Augustin's associates and others,

generally for several hundred thousand dollars for each loan, up to as much as approximately $1.24

million. Based on the evidence investigators have reviewed so far, CHS 2 and Augustin

collectively coordinated applications for PPP loans that are together worth more than $24 million

dollars. The evidence also shows many more PPP loans were attempted but rejected by banks or

their partners, or w ere planned and prepared, but not stlbm itted before CH S 2's arrest. The

evidence suggests that all or nearly all of those loan applications were fraudulent, including

Defendant's loan application and the applications Defendant orchestrated by referring additional

confederates to the conspiracy.

12. lnvestigators have obtained m any other PPP loan applications that CH S 2 has

adm itted he subm itted as part of this scheme, based on falsified docum ents, and have also obtained

draft docum ents used or intended to be used in those applications or others. These applications all

follow the same pattern of fraud many with obviously counterfeit February 2020 bank

statements, and all with fabricated IRS Forms 941 (titled, StEmployer's Quarterly Federal Tax

Return'') with the same indicia of fraud found in Augustin's initial application but generally with

even larger inflated payroll numbers, thus yielding m uch larger loans.4 CH S 2 has explained to

investigators that the figures in the Forms 941 were the product of a formula that allowed him to

start with a target loan amount, and then ivback into'' the payroll figures on the form. He explained

how he used tigures that would produce an average monthly payroll for 20 19 that, when multiplied

by 2.5, would yield the requested loan am ount. In turn, the number of employees reported w as

4 Som e loan applications also included voided checks that appear to t)e falsitied, such as a

purported Bank 5 check that appears to have Ixen produced on a computer and, as the subject line

reads, Sûconverted to PD F,'' rather than a scan of an authentic check.

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chosen based on tk tional payroll figures, chosen to avoid an average em ployee salary that m ight

raise suspicion.

CH S 2 has also explained that he tried to use bank statem ents showing that the

company had a large balance. Because so few companies had such a statement, and likely also

because it was easier than keeping track of their true statelnents, CHS 2 repeatedly subm itted nearreplicas of the same falsified bank statem ents. ln particular, CH S 2 appears to have recycled one

statement each from Bank l , Bank 6, and Bank 7. ln recycling a statement, CH S 2 generally

changed only the account num ber and the accotlnt holder's nalne and address, such that each

version of the statem ent had identical figures and line itenzs throughout the statenzent.

A review of records for bank accounts controlled by CH S 2 at Bank 5 confinn CH S

2's admissions that he received numerous kickbacks, often of approximately 25% of the amount

of the loans, and that he regularly w ired Augustin a share of that kickback in the early stages of

the scheme. CHS 2 explained that they were doing so many loans by the end of M ay that he

changed course, instead w iring larger lump sum s, collecting Augustin's shares of the kickbacks

for m ultiple loans in one w ire.

lnvestigators are still receiving and analyzing records, but based on a preliminary

analysis, as of July 24, 2020, invcstigators had identified a total of $2,367,765.82 in transfers to

CH S 2's accounts from entities that each obtained a sizable PPP loan and that w ere identified in

the PPP tsles seized from CH S 2's and another co-conspirator's residences, as described below

or from individuals associated with those entities.

n e PPP loans identified above as implicated in the foregoing kickback paym ents

to CH S 2 represent only a fm ction of the overall scheme. In executing search w arrants at the

respective residences of CHS 2 and CH S 3. federal agents found stacks of paper printed out and

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organized by entity, containing an dtintake form ,'' fabricated Form s 94 l , or both for each entity.

The intake fonns contained fields for the information needed to fabricate the documents and f5ll

out other aspects of the PPP application: identifying inform ation about the owner and com pany,

as w ell as bank account information for receiving the loan. A section at the end m arked StBELOW

IS OFFICE USE ONLY'' included blank fields for the kiNumber of Employees,'' iiM onthly Payroll

Expense,'' and V:SBA Loan Pre-Approval A mount.'' Between CH S 2's and CH S 3's residences,

investigators seized paper files for PPP loan applications for approxim ately 80 different entities.

Data obu ined from the SBA show ed additional PPP loan applications from

additional entities that text message and email records show had been referred to CHS 2 by

Defendant or other individuals.

The Fraudulent PPP Loan to Defendant's Cb- flay.' Five Plus

18. According to Florida's Division of Corporations website (ûûSunbiz''), Five Plus was

incorporated in 20 1 8 w ith its listed principal address in M iam i, Florida. M CKEN ZIE is listed on

Sunbiz as one of five managers of Five Plus with a separate address in M iam i Gardens, Florida.

According to separate bank records, on or about M ay 26, 2020, M CKENZIE opened a bank

account in the name Five Plus and listed himself as the sole signatory on the account.

19. From on or about M ay 16, 2020 through on or about M ay 19, 2020, an application

and supporting docum ents for a PPP loan w ere electronically subm itted on behalf of Five Plus to

Bank 2 through Bank Processor l . The submitted documents included, among other things: (1)

purported Forms 941 for all four quarters of 2019; (2) a company bank statement for Five Plus;

and (3) two blank checks.

20. The purported Forms 941 show quarterly payroll of almost $300,000 each quarter,

for 10 employees. Each was signed by hand with the name i'Damion M cKenzie'' as the company

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owner, and also Iisted M CKENZIE as the company's designee and as a t*paid Preparer,'' though

he is not a paid tax preparer. The Five Plus Form s 94l follow the sam e style and pattern as the

many other falsified Form s 941 that CH S 2, described above, acknow ledged that he helped create

and subm it in the course of the schem e, including in the indicia of fraud.s IRS records show that

Five Plus did not, in fact, file any Forms 94 1 for any qual-ter of 20l 9 or the first qualter of 2020,

and Florida Department of Revenue records show that Five Plus did not report any wages or

employees for that sam e period.

21 . 'T'he purported company bank statement, which was submitted in electronic, PDF

format, is a clear forgery. First, the statement is not from Five Plus's bank. Second, according to

the document's f5le S'prom rties,'' the statement was created using (SPDFFILLER '' a program used

to edit electronic PDF files, and was ttmodified using i'Ikxt.''

22. ln a letter dated June 2, 2020, Bank Processor 1 informed M CKEN ZIE that his PPP

loan application was rejected. The following reason was stated on the letter for the rejection:

Elunable to verify Applicant's identity from documents subm itted or discrepancies in inform ation

sublnitted.''

5 As noted above, M CKEN ZIE was listed as both owner and paid preparer. Dozens of other

Form s 94l subm itted in this scheme evidence the same error. CH S 2 has adm itted that these

documents share that feature l cause he misunderstood the form, and he (or someone following

his instructions) prepared alI of the Forms 94 l at issue. The content of the forms also indicate

falsification. AlI four quarterly form s are nearly identical, and the four form s for Five Plus are

identical, down to the penny, in reported figures. They also evidence a pattern of payroll spending

that is likely false : each of the quarters shows increases from the first to second to third m onth of

the quarter. For each identical form , the same figures are reported for the tax liability incurred in

the tirst month of each quarter, the same figure for the second month of each quarter (increased

from the first month), and the same figure for the third month of each quarter (increased from the

second month). The result is that the company reports a perfectly repeating cycle of ascending

payroll costs w ithin each quarter, dropping down again at the start of the next quatter. CHS 2 has

explained that this w as due to a formula he used, allocating different percentages of the quarterly

payroll tax liability to each month of each qualer.

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CHS 2 Cbaflr- # to Law Faf/rce- a/ that the Five #/1/,ç Ppp Loan Almlication rFJ,:

Fraudulent

Investigators spoke with CH S 2 about M CKEN ZIE and the Five Plus PPP loan.

CHS 2 stated that he had m et M CKEN ZIE through Augustin. According to CH SZ, the three of

them had discussed M CKENZIE'S PPP loan, as well as M CKEN ZIE*S referrals, for which

M CK EN ZIE w'ould receive a small cut.A s stated above, CH S 2 and A ugustin had already av eed

to share the 25% kickback payments that CHS 2 would usually receive from referrals, including

from M CKENZIE'S referrals.

As to the Five Plus PPP loan, CHS 2 confinmed that the loan application was

fraudulent. CHS 2 stated that he: (1 ) created fbr MCKENZIE an online account fbr Five Plus with

Bank Processor 1 : (2) created and submitted the fake Five Plus bank statement; and (3) created

and subm itted the false Form s 94l . A ccording to CH S 2, however, he em ailed the Form s 94 l to

MCKENZIE unsigned, and then M CKENZIE emailed the forms back to him with sir atures. (As

described below , l have reviewed emails that appear to corrobomte CHS 2's description of this

email exchange.)

25. According to CHS 2, M CKENZIE'S PPP loan application was ultimately rejected.

26. IP session records from Bank Processor 1 corrobomte CHS 2's statement that he

assisted with the submission of the Five Plus loan application. Bank Processor 1 's IP records for

that loan application show that a computer with an IP address (ending in 1 70) associated with CHS

2's residence in Broward County, Florida, logged into the Five Plus loan account as early as M ay

l6, 2020. The session records also reveal subsequent logins by the same IP address (ending in

170), as well as by a computer associated with the Broward County residence of one of Augustin's

associates, and by mobile devices.One of those mobile devices (with an IP addressing ending in

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250) logged into the Five Plus loan account as early as May 16, 2020, and, according to bank

records, also accessed M CKEN ZIE'S personal bank account that day.

27. CH S 2 also stated that, in addition to the Five Plus loan, M CK EN ZIE referred to

him a num ber of friends/associates for the purpose of creating and subm itting additional fraudulent

PPP loans. As stated above, CHS 2 and Augustin would generally share the kickback payments

for these refenuls. CHS 2 stated that, at some point in the scheme, Augustin instructed him not to

pay M CKEN ZIE a portion of the kickback payments that CH S 2 received from M CK EN ZIE'S

referrals. According to CH S 2, when M CKENZIE would inquire about not receiving his cut, CH S

2 w ould refer him to Augustin.

Emails and Text M essazes Cba/-lr- M CKENZIE 's Knowinz Participation in the Fraud

28. As part of its investigation, law enforcement obtained cornm unications betw een

CH S 2 and M CKEN ZIE, including text m essages and em ails. l have reviewed a num ber of these

com m unications, w hich discuss, am ong other things, M CKEN ZIE'S PPP loan and the Ioans for

individuals M CKEN ZIE referred to CHS 2.

29. On or about M ay l 5, 2020, CHS 2 emailed M CKENZIE Form s 94l for Five Plus

for a11 four quarters of 20l 9. The tbnns were filled out (including stating that Five Plus had 10

employees and almost $300,000 in quarterly payroll) but were not sir ed. The same day,

M CK ENZIE em ailed CH S 2 signed copies of the four Form s 941.

On or about M ay 16, 2020, M CKENZIE forwarded CHS 2 an email from Bank

Processor 1 titled, S'Your Paycheck Protection Progam loan has been subm ittedv'' The em ail

stated, in part: iiDam ion, Your application was sent to the SBA to be processed. Based on capacity,

the SBA may take up to a few days to process your application.''

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On or about M ay 20, 2020, M CKEN ZIE texted CHS 2: ûi-l-hey said the voided check

is under review once they done they w ill em ail.'' M CKEN ZIE then texted: 11I dont have a business

account for this business i am going to try to get one open today just in case they ask for it.''

On or about M ay 1 9, 2020, M CKEN ZIE texted CH S 2 w ith inform ation that

appears to relate to a diffel-ent fraudulent loan application, including: (l) a social security number',

(2) date of birth; (3) email address; and (4) employer identification number ($(EIN''). Later that

day, MCKENZIE texted CHS 2: lican you get ENAME REDACTED) at $290k?''

33. O n or about M ay l 9, 2020, CH S 2 separately em ailed M CK EN ZIE a blank intake

information form to be filled out with the personal and business inform ation for M CKEN ZIE'S

refen-als. And in a separate text message, CHS 2 stated: $i1 just sent you a form to f5ll out with each

client its easier with us to upload application w e are swam ped A lso if the corp and home address

are the same just put same on corp address.'' On or about May 2 1, 2020, MCIQENZIE emailed

CHS 2 completed intake forms regarding two referrals.

34. During my review of M CKENZIE'S communications w ith CHS 2, l found what

appears to be information pertaining to at least ten different people and corporate entities. Further

investigation, including review of data collected by the SBA and bank records, to date has

identified PPP loans totaling more than $3.3 million corresponding to these names and entities.

Bank Records Cbl//irpl M CKENZIE'S Knowinz Participation in the Fraud

l have reviewed CHS 2's bank records, which retlect payments to CHS 2 from

MCKENZIE'S referrals as well as payments by CHS 2 to Augustin (who had brought in

MCKENZIE to the scheme). For example, on or about May 26, 2020, CHS 2 received a wire

transfkr in the amount of $122,155 related to a PPP application in the name of a company

(hereinafter 'Ecompany 14'') that MCKENZIE had referred to CHS 2. The same day, from that

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same account, CHS 2 wired $39,970 into one of Augustin' s bank accounts. CHS 2 confirmed that

the paym ent to Augustin represented his share ofthe kickback from Com pany 14.6

36. Bank records and text m essages also retlect paym ents directly to M CK ENZIE fronz

his referrals, follow ed by paym ents from M CKENZIE to CH S 2. For exam ple, on June 8, 2020,

CHS 2 provided M CKENZIE with his bank account information via text message and stated:

SçAfter your money send me 80k.'' M CKENZIE responded, :*Ok.'' Separately, on or about June

8, 2020, M CKENZIE deposited two checks in the amounts of $85,000 and $90,000 from a

com pany M CKEN ZIE had referred to CH S 2. On or about June 1 1, 2020, CH S 2 received a w ire

transfer in the amount of $80,000 directly from Five Plus. n at same day, from the same account,

CHS 2 wired $40,000 to one of Augustin's bank accounts. CHS 2 explained to investigators that

the $80,000 transfer w'as in connection with one of M CKENZIE'S referrals, who had wired the

kickback payment directly to M CK ENZIE instead of CHS 2.

37. Other banking records show deposits consistent w ith M CKENZIE receiving

additional kickbacks. Betw een approxim ately M ay 26, 2020 and July 2, 2020, M CKENZIE

received payments of $20,000, $5,000, and $45,000 from three separate companies. Different

banking records show CHS 2 received separate payments from each of those three companies.

6 Bank records show that on M ay 26, 2020, the same day CHS 2 paid $39,970 to Augustin,

CHS 2 also made a purchase at a jewelry store in the amount of $73,000.

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CONCLUSION

38. Based on the forgoing, I respectfully subm it that there is probable cause to believe

that DAM ION MCKENZIE committed the Target Oflknses.

FtJRTHER Y()IJR AFFIANT SAYE T1 I NA UGHT.

M ICLIAEL BENIVEGNA

Special A gent

I RS-C, I

Attested to by the applicant in accordance

with the requirements Fed. R. Crim. P. 4. 1

by tekphone on this - Day of August, 2020

'iik- llk.-. ............... .

HON. PATRIC K M . CIUN rN

UN ITED STATES M AG IS'I'RATE JUDG I:',

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