FILED

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

NOV - 8 2023

CLERK, U.S. DISTRICT COURT

UNITED STATES OF AMERICA

LASHONDA MOORE (01)

MARLON MOORE (02)

EASTERN DISTRICT OF EXAS

NO. 4:23CRjL(3

INDICTMENT

THE GRAND JURY CHARGES:

At all times relevant to this Indictment:

The Defendants and Relevant Entity

1. Defendants LASHONDA MOORE and MARLON MOORE were wife

and husband, and residents of Prosper, Texas.

2. BINT Operations LLC was a Texas limited liability company, formed in

August 2020. Defendants LASHONDA MOORE and MARLON MOORE controlled

BINT Operations and were the signers on its bank accounts.

Relevant Background on Pyramid Schemes

3. Pyramid schemes are illegal promotional programs whereby (a) new

participants are induced to pay money into the scheme in exchange for the right to recruit

new participants, and (b) participants profit in the scheme derives from their recruitment

of new participants rather than the sale of a product or service. Pyramid schemes inevitably

collapse because they require an ever-expanding base of new participants for the existing

participants to realize a profit on their initial investments.

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Overview of the Conspiracy a d Scheme to Defraud

4. From in or around June 2020 and continuing until in or around June 2021,

defendants LASHONDA MOORE and MARLON MOORE conspired and agreed with

each other to create and run an illegal pyramid scheme called Blessings in No Time

( BINT ) from their home. BINT was a chain-referral pyramid scheme that targeted the

African American community during the COVID-19 pandemic with false and misleading

statements and promises regarding high returns, guaranteed refunds if participants were

unsatisfied with the program, the ability to earn hundreds of thousands or millions of

dollars, and the supposed legitimacy of BINT.

The Purpose of the Conspiracy and Sche e to Defraud

5. The purpose of the conspiracy and scheme to defraud was for defendants

LASHONDA MOORE and MARLON MOORE, and others, to unlawfully enrich

themselves by operating an illegal pyramid scheme and to conceal their scheme from

outside scrutiny.

Manner and Means of the Conspiracy and Scheme to Defraud

6. The manner and means by which defendants LASHONDA MOORE and

MARLON MOORE sought to and did accomplish the purpose of the conspiracy and

scheme to defraud included, but were not limited to, the following:

7. Defendants LASHONDA MOORE and MARLON MOORE promoted

BINT to African Americans as a profitable and legitimate investment opportunity, when in

truth and in fact they knew they were operating an illegal pyramid scheme.

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8. Defendants LASHONDA MOORE and MARLON MOORE made false

and misleading promises in marketing material and video presentations to potential and

existing BINT participants that they would make high returns and that any dissatisfied

participants could receive a full refund, when in truth and in fact it was impossible for all

participants to receive such returns or refunds.

9. Defendants LASHONDA MOORE and MARLON MOORE structured

BINT so that it operated on playing boards that had four levels: Fire, Wind, Earth, and

Water. Each playing board had eight Fire positions on the outside, four Wind positions

closer in, two Earth positions next to the center, and one Water position at the center. Each

BINT participant started in the scheme as a Fire on a board assigned to them. The Fires

were directed to “bless or pay the Water either $1400 or $1425, so that the Water received

$11,200 or $11,400 in total. Once all Fires paid the Water, then the board split into two,

and every Fire moved into a Wind position. Every Wind then had to recruit two Fires, and,

once the new Fires made their payments, the board split and the Winds became an Earth

on their respective new boards. After one more round of Fires were recruited and made

their payments, the board split again, and the Earths finally became Waters and were

eligible to receive their payments from the Fires. In other words, eight new participants

had to be recruited into the scheme for a single earlier participant to receive a return on

their initial investment.

10. On occasion, due to difficulties in recruiting enough new participants,

defendants LASHONDA MOORE and MARLON MOORE changed the payout structure

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so that a participant in the Water position would receive 4 payments from Fires, totaling

$5,700, rather than 8 payments. The purpose of this change was to make it faster and easier

for participants to receive a return on their initial investment. They called this change

fusion. 

11. Starting in or around August 2020, defendants LASHONDA MOORE and

MARLON MOORE required BINT participants to use an online platform called Conecmi

to populate playing boards, coordinate payments between Fires and Waters, and facilitate

the splitting of boards. BINT participants had to pay an $85 monthly fee to access

Conecmi. Members applied to join the program through the website bintapp.com.

12. Defendants LASHONDA MOORE and MARLON MOORE profited from

the scheme in two primary ways: (1) by placing themselves or family members in the Water

position on multiple playing boards so they would receive the payments from participants

in the Fire position; and (2) diverting to themselves substantial sums from the monies

participants paid to Conecmi every month.

13. Defendants LASHONDA MOORE and MARLON MOORE attempted to

avoid scrutiny by financial institutions and payment processors by instructing participants

who used services such as CashApp, Venmo, PayPal, and Zelle to make their required

Fire payments to avoid using the words “gift or “blessing in the reference or memo

lines when sending payments.

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14. Defendants LASHONDA MOORE and MARLON MOORE attempted to

avoid detection and scrutiny by legal authorities by prohibiting BINT participants from

posting about BINT on social media on pain of being kicked out of the program entirely.

15. Defendants LASHONDA MOORE and MARLON MOORE falsely

reassured participants that BINT was operating within legal boundaries by, among other

means, referring to the supposed participation in BINT of government employees at the

IRS and the Pentagon.

16. In total, as part of their illegal pyramid scheme, defendants LASHONDA

MOORE and MARLON MOORE recruited over 8,000 individuals into BINT and caused

participants to pay over $10 million into the program.

COUNT ONE

Violation: 18U.S.C. § 1349

(Conspiracy)

17. Paragraphs 1 through 16 of this Indictment are realleged and incorporated by

reference as though fully set forth herein.

18. Beginning in or around June 2020, and continuing until in or around June

2021, in Denton and Collin counties, within the Eastern District of Texas, and elsewhere,

defendants LASHONDA MOORE and MARLON MOORE did knowingly and

intentionally, that is, with the intent to advance the conspiracy, combine, conspire, and

agree with other individuals, known and unknown, to commit certain offenses against the

United States, namely, wire fraud, that is, to knowingly, and with the intent to defraud,

having devised and intending to devise a scheme and artifice to defraud, and to obtain

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Page 5 of 11
money and property by means of materially false and fraudulent pretenses, representations,

and promises, knowing such pretenses, representations, and promises were false and

fraudulent when made, transmit and cause to be transmitted, by means of wire

communications in interstate and foreign commerce, writings, signs, signals, pictures, and

sounds, for the purpose of executing such scheme and artifice, in violation of Title 18,

United States Code, Section 1343.

Purpose of the Conspiracy

19. The Grand Jury realleges and incorporates by reference paragraph 5 of this

Indictment as a description of the purpose of the conspiracy.

Manner and Means of the Conspiracy

20. In furtherance of the conspiracy, and to accomplish its object, the methods,

manner, and means that were used are described in paragraphs 6 through 16 of this

Indictment and are realleged and incorporated by reference as though fully set forth herein.

All in violation 18 U.S.C. § 1349.

COUNTS TWO THROUGH SIX

Violation: 18 U.S.C. § 1343

(Wire Fraud)

21. Paragraphs 1 through 16 of this Indictment are realleged and incorporated by

reference as though fully set forth herein.

22. On or about the dates specified as to each count below, in Collin and Denton

counties, within the Eastern District of Texas, and elsewhere, defendants

LASHONDA MOORE and MARLON MOORE

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did knowingly, and with the intent to defraud, having devised and intending to devise a

scheme and artifice to defraud, and to obtain money and property by means of materially

false and fraudulent pretenses, representations, and promises, knowing such pretenses,

representations, and promises were false and fraudulent when made, transmit and cause to

be transmitted, by means of wire communications in interstate and foreign commerce,

writings, signals, pictures, and sounds, for the purpose of executing such scheme and

artifice.

Purpose

23. The Grand Jury realleges and incorporates by reference paragraph 5 of this

Indictment as a description of the purpose of the scheme and artifice to defraud.

Scheme and A tifice to Defraud

24. The Grand Jury realleges and incorporates by reference paragraphs 6 through

16 of this Indictment as a description of the scheme and artifice to defraud.

Use of the Wires

25. On or about the dates specified as to each count below, LASHONDA

MOORE and MARLON MOORE, in the Eastern District of Texas, and elsewhere, for

the purpose of executing the aforesaid scheme and artifice to defraud, and attempting to do

so, did knowingly transmit and cause to be transmitted, by means of wire, radio, and

television communication, writings, signals, pictures, and sounds in interstate and foreign

commerce:

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All in violation of 18 U.S.C. § 1343.

COUNTS SEVEN THROUGH NINE

Count On or About Date Description of Interstate Wire

2 August 5, 2020

Interstate wire transfer of approximately

$1,400.00 from Victim CM in Arkansas to

CashApp account ending in ay9y in the Eastern

District of Texas.

3 August 21, 2020

Interstate wire transfer of approximately $85.00

from Victim DP in the Eastern District of Texas

to Conecmi LLC s account with Stripe Inc.

4 September 17, 2020

Interstate wire transfer of approximately

$1,425.08 from Victim SD in Arkansas to

CashApp account ending in gy5n in the Eastern

District of Texas.

5 September 23, 2020

Internet video live stream broadcast from within

the Eastern District of Texas to BINT

participants, outside the state of Texas

6 November 7, 2020

Internet video live stream broadcast from within

the Eastern District of Texas to BINT

participants, outside the state of Texas

Violation: 18 U.S.C. § 1957

(Money Laundering)

26. Paragraphs 1 through 16 of this Indictment are realleged and incorporated by

reference as though fully set forth herein.

27. On or about the dates specified as to each count below, in Collin and Denton

counties, within the Eastern District of Texas, and elsewhere, defendants

LASHONDA MOORE and MARLON MOORE

did knowingly engage and attempt to engage in a monetary transaction affecting interstate

and foreign commerce, in criminally derived property of a value greater than $10,000, such

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property having been derived from a specified unlawful activity, that is, wire fraud, in

violation of Title 18, United States Code, Section 1343, each transaction constituting a

separate count:

All in violation of 18 U.S.C. § 1957.

Count On or About Date Description of Monetary Transaction

7 November 20, 2020

Electronic transfer of $20,000 from account at

BBVA USA Bank (now known as PNC Bank)

ending in 4252 in the name of MARLON

MOORE to loan payment number ending in

0633.

8 November 25, 2020

Check card payment of $15,937.06 from

account at Bank of America ending in 1111 in

the name of BINT Operations LLC to Paradisus

Los Cabos Beach Resort in Los Cabos, Mexico.

9 January 19, 2021

Electronic transfer of $446,761.74 from account

at Bank of America ending in 1111 in the name

of BINT Operations LLC to mortgage lender of

the property at 3100 Kennington Drive, Prosper,

Texas.

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NOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE

18 U.S.C. § 981(a)(1) and 28 U.S.C. § 2461

As a result of committing the offenses as alleged in this Indictment, defendants shall

forfeit to the United States pursuant to 18 U.S.C. § 981(a)(1) and 28 U.S.C. §2461 any and

all property, real or personal, involved in or traceable to property involved in the offense,

including proceeds obtained directly or indirectly from the offense, and the following:

Cash Proceeds

A sum of money equal to at least $2,000,000 in United States currency, and all

interest and proceeds traceable thereto, representing the amount of proceeds

obtained by defendants as a result of the offense alleged in this Indictment, for

which the defendants are personally liable.

Substitute Assets

If any property subject to forfeiture, as a result of any act or omission by defendants:

(a) cannot be located upon the exercise of due diligence;

(b) has been transferred or sold to, or deposited with a third party;

(c) has been placed beyond the jurisdiction of the court;

(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be subdivided

without difficulty,

it is the intent of the United States, pursuant to 21 U.S.C. § 853 (p), to seek forfeiture of any

other property of defendants up to the value of the above forfeitable property, including

but not limited to all property, both real and personal, owned by defendants.

By virtue of the commission of the felony offenses charged in this Indictment, any

and all interest defendants have in the above-described property is vested in the United

States and hereby forfeited to the United States pursuant to 18 U.S.C. § 981(a)(1) and 28

U.S.C. § 2461.

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A TRUE BILL

GRAND JURY FOREPERSON

GLENN S. LEON

CHIEF, FRAUD SECTION

CRIMINALDIVISION,

THEODO NELLER

Trial Att ey

WILLIAM JOHNSTON

Assistant Chief.

Date

DAMIEN M. DIGGS

UNITED STATES ATTORNEY

NATHANIEL KUMMERFELD

Assistant United States Attorney

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA §

V.

§

§ NO. 4:23CR/ M 

LASHONDA MOORE (01) §

MARLON MOORE (02) §

Violation:

NOTICE OF PENALTY

COUNT ONE

18U.S.C. § 1349

(Conspiracy to Commit Wire Fraud)

Penalty: A fine of $250,000, or twice the pecuniary gain to the defendant or

loss of the victim(s), whichever is greater; imprisonment for not

more than 20 years; and a term of supervised release of not more

than 3 years.

COUNTS TWO THROUGH SIX

Violation: 18U.S.C. § 1343

(Wire Fraud)

Penalty: A fine of not more than $250,000, or twice the pecuniary gain to the

defendant or loss of the victim(s), whichever is greater; and/or

imprisonment for not more than 20 years; and a term of supervised

release of not more than 3 years.

COUNTS SEVEN THROUGH NINE

Violation: 18U.S.C. § 1957

(Money Laundering)

Penalty: A fine of not more than $250,000, or twice the value of the

transaction, whichever is greater; and/or imprisonment for not more

than 10 years; and a term of supervised release of not more than 3

years.