AO 91(REv. I I/11) Criminal Complaint

UNmBo SrarBs Drsrzucr CouRr
for the

Diskict of Columbia
United States of America

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IMRAN AWAN

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Case l,lo:'1 :1 7-mj-524
Assigned To: Magistate Judg€ Deborah A. Robinson
Date Assigned: 07 t24t2,17
Descaiption: Complaint & Anest l/lhnant

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Defendan(s)

CRIMINAL COMPLAINT
I, the complainant in this
On or about the date(s)

of

case, state thal

SEE ATTACHED

Dishict of

the following is true to the best of my knowledge and belief.

AFFIDAVIT

COLUMBIA

in the county of

, the defendant(s)

Code Section

18 USC 1344

in the

violated:

Of/ense Description

BANK FitAUD

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This criminal complaint is based on these facts:
SEE ATTACHED AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

d

Continued on the attached sheet.
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Conplainart's signawe

BRANDON C MERRIMAN, SPECIAL AGENT
Prinled name and lille

Swom to before me and signed in my presence.

Date'.

07 t24t0217

J
City ard state:

WASHINGTON, DC

dge's signah/re

DEBORAH ROBINSON
Prinled name and litle

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 UMTED STATES DISTRI(
FORTHE DISTRICT OF CI
UNITED STATES OF AMERICA

Case l,lo:1:17-mi524
Assigned To: Magistate Judge Deborah A. Robinson
Date Assigned: 07241201 7

Description: Complaint & Anest lr\hnant

Magistrate No.

v

Violation:
18 USC S 1344 (Bank

IMRANAWAN,

Fraud)

Defendant.

I, Brandon C. Merriman, being duly swom, depose and state:

INTRODUCTION

1.

I make this affidavit in support of a criminal complaint charging IMRAN AWAN

('AWAN-) with knowingly engaging ia a scheme or artifice to defraud the Wright

Patr'nan

Congressional Eederal Credit Union @ereinafter, "CFCU') to obtain money owned by, and under
the custody and control ofCFCU, by mears offalse and fraudulent pretenses, representations, and

promises, in violation of Title 18, United States Code, Section
submitted in support of

a.n

i344. This affida'i'it is atso

arrest warrant.

AGENT BACKGROT'ND

2.

I

arna Special Agent ("SA") of the Federal Burcau of Investigation

have been so emplctyed since January

("FBI") and

2016. My principal duties include the investigation fo

criminal allegations of bribery and corruption involving public officials, mail atd wire fiaud, and

gove[unent fraud. I have training and experience in ttre enforcement of the iaws of the United
States, including the preparation and presentation of affidavits in support of complaints and arrest

warrants. I have had both training arid expedenca in the investigation of crimes involving fraud
and have worked

with other FBI agents who have such expericnce,

and. who have provided me

with additional information about such crimes. I have received faining in the investigation of
various federal crimes from the FBI Academy in Quantico, Virginia-

1

 SOURCE OF INFORMATION

3.

The facts and information contained in this affidavit are based upon my persgnal

knowledge of the intestigation, hformation obtained ftom other law enforcement persorurel, a
review of documents related to this investigation, and information obtained liom interviews and

amiysis. A1l observations referenced in this affidavit tlat were not made by me were relayed. to
me by the person who made such observation. Unless specilically indicated, all conversations and
statements described in this af&davit are relaled in substance and in part only and are nbt intended

to be a verbatim recitation of such statements. When I specify that a communication occurred on
a specific date,

it

should be construed that the commuoication occurred "on or aboutl' the date

specified-

4.

This affidavit is submitted for the limited purpose of establishing probable cause.

Because this affidavit is limited in pu4)ose, it does not coutain aI[ information known to me, other

law enforcement officers, 0r the United States Govemment.

FACTS SUPPORTIN G PROBABLE CAUSE

5.

Based upon a review of records, your AfEant knows that

AWAN married his wife,

HINA ALVI (*AfVI"), sometime before 2014. They remain married.

6.

Based upon records obtained from the Fairfax County Courthouse, ALVI

purchased 4809 Sprayer Steet, Alexantlria, Virginia 22309 (herenafter, the "sprayer Sfeet
Property'') on November 7, 2014, for $187,500.00.

7.

CFCU was a fioancial institution with deposits insured by the Federal Deposit

Insurance Corporation. CFCU was in the business of, among other things, loaning money to
individuals who used their primary residences to secure the loans. One of those loans was knowrr
as a

'trome equity line of credit" or "IIELOC" where an individual could pay off an original loaa

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 and/or take periodic cash advances up to a specific maximum amorurt of money (with funds
available to be drawn against

tle line of

credit

ifthe individual

paid back some of the borrowed

money).

8.

Based upon a review of records that your

Affiant obtained from CFCU, AIVI

applied for a IIELOC loan from CFCU for the Sprayer Street Property on or about December 12,

2016. As part of that loan application, ALM submitted to CFCU her federal tax retums for 2Ol4
and 20

1

5

.

Those tax retums showed that

ALVI filetl j ointly with

her husband, AWAN, and that

they listed no rental income on their tax forms.

9.

As part of

ALVI's HELOC ioaa application,

she also listed her W2 income for

year

2015 as being $157,531.00, which matched the amount of income listed on her actual W2 issued
by the U.S. House of Representatives. On
she had aay "Other Income,"

ALVI did

a

portion ofher HELOC loan application asking whether

not list aaything, again indicating that she was not eaming

rental ilcome.

.

10.

Based upon a conve$ation

tiat

your Affiant had with the Assistant Vice President

of Security at CFCU, your Affiant knows that CFCU

does not normally provide

IIELOC loans

where the housc used to secure that loan is being used as rentai property. This is because rental
properties are considered riskier forrns of collateral than traditional primary residences.

i1.

On July 10,2017, U.S. Capitol Police Special Agent Sean A. Camp interviewed

Person A in reference to this investigation. Person A stated that Person A and their spouse, Person

B, rented the Sprayer Street Property fiom June/July 2015 through October 2016. Person A stated

that they found the Sprayer Street Property tirough a website that lists rental properties. Person

A

stated that her primary point of contact regarding the rental

AWAN, but that Person A also had interactions with

3

AI\ll

as

ofthe Sprayer Street Property

well.

Person

was

A stated that they paid

 approximately $2,000 per month for rent and that the rent check was written to SURIAYA

BEGIIM (.'BEGIIM'). Based upon information and beiief, I know that BEGUM is ALVI's
mother.

12.

Furthermore, on July 24, 2017, Special Agenl Camp and your Affiant interviewcd

Person C, who we discovered using law enforcemcnt databases. Person C infomred us that Person
C resided at the Sprayer Street Property from December 2016 through May 2Ol7,aad that Person
C signed a six-month lease to that effect whereby Person C paid $2,1 00 in rent per month to

ALVI.

PersonCalsoprovidedSpecia1AgentCampandyourAffiantwithacopyof,that1ease.

13.

The application for the I{ELCO loan also asked, "Do you intend to occupy the

property as your primary residence?"
"purpose of refinance," and

14.

ALVI

ALVI

answered.

'Yes." Thc application

also asked for the

answered, "Cash out home improvement."

The HELOC loaa application for the Sprayer Street Property also asked for the

"sex" of the person completing the fonn. The person completing the form listed "male." The
application also asked for the phone number of the individuat completing the form. The phone
number (202) 604-7650 was listed. Your Affiant knows, from records received from Verizon, that

the subscriber listed for this number is AWAN. In addition, a current tenant of another rental
prcperty ownod by ALVI infomred Your Affiant that the tenant communicates with AWAN.using
the (202) 604-7650 phone number.

15.
whether

The HELOC loan application also asked

ALVI to list all rea.l

it was being used for rental income. ALM listed the Sprayer

estate she owned, and

Street Property and stated

that no rcntal income was behg eamed on that property. ALVI also listed a property at 4387

Pembrook Village Dr., Alexandna. V bg)a1a 22309 (hercinafter, the "Pembrook Village
Property''). and stated that she eamed $1,650.00

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rental ilcome on that property.

 16.

On December 12,2016, at 12:37:48 PM, CFCU sent an invitation to

AIVI

to

electronically sign. the TIELOC loan d.ocuments to the email address "imranawanl @grnai1.com.i'
Tbrough ttie course of this investigation, and through interviews and subpoena returns, your

Aftrant has iearned that the email address "imranawanl@grnail.com" was used. by AWAN to
communicate with tcnants and financial institutions. Based on a review of the contents of this

email account, your Affiart does not believe that this email account was never used by
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AIVI
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On December

12

,2O16, at 12:39:1

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AIVI.

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PM, records obtained ftom CFCU showed that

coasented to sigrr the HELOC loaa documents elecffonically. On December 12,2016, at

2 :4 I : I

9 PM, these records showed that

AL\rI electronically sigred the HELOC loan application.

The Intemet Protocol ("IP") address used to consent and
143.231.249.139

.

sip

the HELOC loan documents was

Your affiant knows that this IP address belongs to the U.S. House of

Representatives, whose servers are located within the District of Columbia.

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18.

On January 3,201'7, a loan officer (the "Loan Officef') at CFCU who was

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processing the HELOC loan application scnt an email to "imranawan l @gmail.com" asking the

following questions:
Good Aftemoon Mr. [slc]

Alvi,

I received your flle back ftom the Underwritet. There are a few items needed before

a final approval can be ieceived.

I

have listed below the pending documents

needed:

1.

4.

Please provide a copy of the cunent lease agroement for rental
Village Dr. Alexaadria Virginia 22309

write a statement why 2014 and 2015 tax retums
income for 4387 Pembrook Village Dr. Alexandria VA
Please

axe

43 87

Pembrook

not showing rental
I

Thank you

!

5

 19.

On January 4, 2017, an email was sent fiom imranawan 1@gmail.com to the I-oiur

Officer at CFCU in response to the Ioan Officer's January 3d emai1. Atiached to the email was a
letter that stated:
January 3, 20 t 7

To Whom It May Coneem:
4387 Pembrook Village Dr. Alexaadria YA 22309 property was not on my 2014
and 2015 tax rehrrns as a rental because it was not rent out during those years.
Regards,

Hina

Alvi

On that same day, another email was also sent from imranawanl @gmail.com to the Loan Officer

at CFCU. Attached to that email was a Residential l-ease Agreement dated February 4,2016,
between

ALVI

and her mother, BEGUM, for the Pembrook Village Property. dss6lding to

Residential Lease Agreement,

.

l, 2016 and endirg on March t, 2018.

. As part of this investigation, your Affiant performed a search of law enforcement

databases and found individuals associated

E.

D and Person

with the Pembrook Village Property, including Person

On July 20,2017, your AfEant spoke to P'erson D and Person E, and they

informed your Aftrant that they were renting the Pembrook Village Property from

D and Person.E also provided your Affiant with a Lease Agreement
between

ALVI

Inly 28,2017

21,

s

ALVI was renting the Pembrook Village Property to BEGII\4 for

24 months, commencing on March
20

tl

and Person D ard Person

E.

ALVI.

Person

dated August 16,2014,

The term of the lease was August 16,2014 through

.

On January 5,2017,the following email was sent from irnranawan l@grnaii.com

to the Loan Officer:

Hi [Loan Officer]
6

 When will you have an answer on both of our HELOC approval? Ar:dwhat are the
soonest closing dates please? Kindly advise.. ..

22.

On January 5,2017, the Loan Officer sent an email to imranawan 1@gurail.com

stating that the HELOC loao was approved for the Sprayer Street Property in the amount of
$165,000.00. That same day, an email was sent from imranawan I @gmail.com to the Loan Officer
accepting the HELOC lo4n.

.

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.

.

As part

Afftdavit.

On that

The closing for the HELOC loan occurred on or about Janu ary 12, 2017

of that closing,

ALVI

was asked to execute an Oqcupancy and Financial Status

affidavit, which was used as a materia"l inducement to CFCU providing the HELOC 1oan, ALVI
stated that the Sprayer Street Property was being used as her "principal residence" and that:

"Borrower will occupy and use the Property as Borrower's principal
residence within 60 days after Borrower signs the Sscurity Instrument.
Borrower will continue to occupy and use the property as Borrower's
principai residence for at least one (1) year from the date that Borrower first
occupies the Property.".

As irdicated above, as of January 12,2017, Person C was residing in t\e Sprayer Street
Property and had lease agreement allowing Person C to reside there until June 2017.

24.

Based on our investigation, which included physical surveillance and interviews

of

individuals, your Affiant leamed that AWAN and ALVI wcre residin g at 9667 Hawkshead Drive,

Lorton, Virginia 22079 unltl on or about February 16,2017. On or after February 16,2017,

AWAN and AI\II have resided a two other residences, neither of which is the Sprayer Street
Property.

25.
submitted by

On January 18, 2017 , at 12:09 1!m, an intemational wire hansfer request form was

ALVI

at CFCU's branch at the Longworth House Office Building, in the District

of

Columbia, in. the amount of $283,000.00, to two individuals in Faisalabad, Pakistan. On thc

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 intemational wire request form submitted by ALVI, she provided the contact number of (2O2) 2250346 and an email address of imranawanl @grnai1.com.

26.

On January 18, 2017 , at 3:23 pm, a representative from CFCU called (2O2) 225-

0346 and requested to speak \nifli ALVI in regards to the v/ire tralsfer request. The person
answering the call, who was a male, pretended that he was

ALVI.

On the cal1, the representative

asked the maa to verify the address of where the wire was being sent and the purpose of the

outgoing

wire. The male

spedking to the represent itive said that the purpose of the wire was

"firneral arrangements." The CFCU representative then stated that "firneral arrangements" may
not be an acceptable reason for the wire. The male speaking to the representative then rcsponded
that he would look.online for aa acceptable reason for.the

wire. After

a long pause, the male said

that the reason for tle wire was "buying property." The representative accepted that reason and
initiated the wire tra:rsfer to Pakistan. Bank records ghow that $165,000.00 of $283,000.00 wired
to Pakistan was ftom the HELOC loarr for the Sprayer Street Property.

27.

On March 5, 2017, your Affiant, along with agents from the FBI a:rd U.S. Capitol

Police, approached

ALVI

Airport, in Dulles, Virginia. AL\{I was about to

at Dulles Intemational

board Qatar Air1ines, Flight 708, to Doha, Qatar, on.her way to Lahore, Pakistan.

ALVI was with

her three children, who your Affiant later learned were abruptly taken out of school without
notifying the Fairfax County Public School System. ALVI had numerous pieces of luggage with
her, including cardboard boxes.

A

secondary search

of those items revealed tlat the

boxes

contained household goods, clothing, and food items. U.S. Customs and Border Protection
conducted a search of

ALVI's

bags immedia&ly prior to her boarding the plane and located a total

of $12,400.00 in U.S. cash inside. AJ-VI was permitted to board the flight to Qatar and she and
her daughters have not retumsd to the United States.

ALVI has a retum flight booked for

a date
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 in

September

2017. Based on your Affiant's

observations

experience and training, your Affiant does not believe that

at Dulles Airyort, ard upon his

ALVI

has any intention to retum to the

United States.

28.

AWAN

has purchased a

flight on Qatar Airlines, Flight 708, departing from Dulles

Intemational Ajrport on July 24, 2017, to Doha, Qatar, at 8:45 pm, and then to [,ahore, Pakistan.
He has purchased a retum flight for a date in January 20 1 8 .

CONCLUSION

29.

For the foregoing reasons, your Affiant submits there is probable cause to believe

that AWAN and his wife,

ALVI,

engaged in a scheme to defraud CFCU, by obtaining a

IIELOC

loan based on two material misreprescntations made to CFCU, a financial institution with deposits

insured by ttre FDIC: (1) a misrepresentation regarding ttreir use ofthe Sprayer Street Property as
a primary residence and not as a rental property; and (2) a separate misrepresentation; regarding

ALVI's intention to use the Sprayer Street Property

as her permanent residence

following the

closing of the HELOC loan even though she was renting the property to Person C at the time.
These misrepresentatiors were material

ald

caused CFCU to provide

AWAN and

his

with a IIELOC loan in the amount of $165,000.

C. Mcrriman, Special Agent
Federal Bureau of lnvestigafion

REMEWED:

Michael
Assistant United States Attorney

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wife, ALV.I,