Case 8:18-mj-02452-GLS Document 1 Filed 09/07/18 Page 1 of 1
AO 91 (Rev. 11/11) Criminal Complaint

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UNITED STATES DISTRICT COURT
for the

SEP - 72018

District of Maryland
United States of America

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V.

TARE STANLEY OKIRIKA

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BY

AT GREENBELT
CLERK, U.S. DISTRICT COURT
DISTRICTOF MARYLAND I/Erupt

Case No

Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of
District of

06/24/2017 through 08/01/2018
Maryland

in the county of Prince George's & elsewhere in the

, the defendant(s) violated:
Offense Description

Code Section

18 U.S.C. §§ 1343 and 1349

Wire fraud and conspiracy to commit wire fraud

This criminal complaint is based on these facts:
See attached affidavit.

cif

Continued on the attached sheet.

Complainant's signature

Special Agent Jarred T. Medenwald, USSS
Printed name and title

Sworn to before me and signed in my presence.

Date:

9 [Oil

lo r3ovit
Judge's signature

City and state:

Greenbelt, Maryland

Hon. Gina L. Simms, U.S. Magistrate Judge
Printed name and title

 •FILED
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Case 8:18-mj-02452-GLS Document 1-1 Filed 09/07/18
Page 1 of 17
•LOGGED  REC
Y
ENTERED
SEP

EGW: USA° 2018R00264

- .7 2018

AT GREENBELT
CLERK U.S. DISTRICT COURT

IN THE UNITED STATES DISTS,ICT effifirrARYLAte DEFtny
FOR THE DISTRICT OF MARYLAND
UNITED STATES OF AMERICA
Case No. CILS" la t

V.

-

Filed Under Seal

TARE STANLEY OKIRIKA,
Defendant.
*******

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT
I, Special Agent Jarred Medenwald, being first duly sworn, hereby depose and state as
follows:
INTRODUCTION &,AGENT BACKGROUND
1.

I am a Special Agent with the United States Secret Service ("USSS"), assigned to

the Washington Field Office, National Capital Region Fraud Task Force ("NCRFTF"). I have
been a Special Agent with the USSS since May 2016. I have personally conducted or
participated in numerous investigations involving wire fraud, bank fraud, identity theft, access
device fraud, and money laundering. Further, I have received training on the aforementioned
types of financial crimes investigations through both the Criminal Investigator Training Program
at the Federal Law Enforcement Training Center in Glynco, Georgia, and the Secret Service's
Special Agent Training Program at the Rowley Training Center in Beltsville, Maryland. I am
currently assigned to conduct investigations involving violations of the federal criminal code,1
including money laundering and wire fraud. As a Special Agent with the USSS, I am authorized
to execute arrest warrants issued under the authority of the United States.

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2.

The statements in this affidavit are based on my personal knowledge and

observations during the course of this investigation; information observed by or known to other
law enforcement agents or officers that they conveyed to me; my personal review of records,
documents, and other physical evidence obtained during the investigation; and information
gained through my training and experience. Because this affidavit is being submitted for the
limited purpose of establishing probable cause for the charges listed below and securing an arrest
warrant, I have not included each and every fact known to me concerning this investigationL The
investigation at issue is being conducted by the Department of Homeland Security Office of
Inspector General ("DHS OIG"), the Social Security Administration Office of Inspector General
("SSA OIG"), and the USSS.
3.

I make this affidavit in support of a criminal complaint and arrest warrant for

TARE STANLEY OKIRIKA (hereinafter referred to as OKIRIKA).
4.

Based on my training, experience, and the facts as set forth in this affidavit, I

respectfully submit that there is probable cause to believe that between on or about June 24,
2017, and on or about August I, 2018, OKIRIKA violated and conspired to violate specific
federal statutes as outlined below, including 18 U.S.C. § 1343 (wire fraud) and 18 U.S.C. § 1349
(conspiracy to commit wire fraud), as described herein.
PROBABLE CAUSE
Regulatory Background
5.

The Federal Emergency Management Agency ("FEMA"), an agency of DHS,

provides emergency benefits and compensation for damage to victims who are affected by
declared national emergency disasters. An individual in an area affected by a national disaster s
immediately eligible for $500.00 in compensation, deemed Critical Needs Assistance ("CNA"),
I
in order potentially to purchase life-saving or life-sustaining materials, although this assistance is
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provided in the form of funds with no spending limitations and paid to the victim in a manner of
his/her choosing, which can include being paid onto pre-paid debit cards.
6.

The SSA pays Social Security benefits to, for example, individuals who have met

their retirement age, which may be as early as age 62, and the benefits are paid to the individual
in a manner of his/her choosing, which can include being paid onto pre-paid debit cards.
7.

Likewise, the Department of Labor ("DOL") administers unemployment and

disability compensation to eligible workers, and those benefits are paid to the individual in a
manner of his/her choosing, which can include being paid onto pre-paid debit cards.
Background on Green Dot Pre-paid Debit Cards
8.

Green Dot pre-paid debit cards are pre-paid debit cards that can be purchased at

convenience and grocery stores nationwide and, upon registration, can be funded by Automated
Clearing House ("ACH") electronic funds transfers in the same manner as a bank account. Each
card has a unique number and must be loaded with an initial dollar amount by the card purchaser,
usually $10.00 or $20.00 cash. The card purchaser may remain completely anonymous during
the purchase of the card and, in many instances involving criminality, will take steps to hide
his/her identity and appearance from the seller of the pre-paid card. A card may then be
registered online at GreenDot.com. For registration, individuals can use any real individual's
name and address (Green Dot does work to verify that names and addresses match), and can
register the card anonymously from a mobile phone or the Internet. Sometimes, individuals
perpetrating fraud schemes will register the cards using the same stolen identities that they are
otherwise exploiting. They may also use entirely different stolen identities or, on occasion, their
own identities.
9.

Upon registration of a Green Dot card, Green Dot issues an account number and

provides a routing number for Green Dot Bank. Although Green Dot does confirm that the
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identifying information provided upon registration of a card matches a real person, a Green Dot
card, unlike most bank-issued credit and debit cards, does not require that an activation code or
Personal Identification Number ("PIN") be mailed to the registered cardholder. Rather, each card
is sold with a PIN which can be used to withdraw funds from ATMs or otherwise fund purchases
in the manner of a debit card.
10.

After this point, individuals perpetrating fraud schemes can put money onto Green

Dot debit cards through a variety of means. Sometimes, funds are put onto cards directly from
defrauded individuals' bank accounts, using that stolen information. Individuals perpetrating the
fraud scheme at issue in this case may and did file false disaster assistance claims with FEMA
and/or false claims for unemployment or disability benefits and/or false claims for a tax refund
and/or Social Security benefits claims using the stolen identities of multiple individuals,
including name, address, Social Security Number ("SSN"), and other personal identifiers. These
false online claims were often made through government websites such as the FEMA website,
disasterassistance.gov.
11.

When making such claims online, the individuals perpetrating this fraud input the

account number and routing number from the Green Dot debit card into the claim form in order
to receive the disaster assistance or other government program funds such as Internal Revenue
Service ("IRS") tax refunds, SSA benefits, or DOL benefits onto the Green Dot debit card. The
false claim proceeds (disaster or other government program funds) were then ACM-deposited
directly onto the Green Dot debit card from the government, constituting a theft of public funds.
12.

Green Dot debit cards do not function like a traditional pre-paid gift card in

certain respects. For instance, for Green Dot debit cards, users are able, if the cards are registered
with Green Dot, to log into an online account portal or a mobile application to control funds as
well as utilize the debit card for purchases or withdrawals. According to the Green Dot website,
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users are also able to move available funds from their account balance to a "money vault" which
acts much like a savings account.
Summaty of Relevant Facts
13.

An investigation was initiated in October 2017 by the DHS OIG to look into

allegations of identity theft and fraudulent claims for assistance as a result of Hurricanes Harvey,
Irma, and Maria, and the California wildfires. During the investigation, law enforcement learned
that, in 2016 and 2017, hundreds of Green Dot debit cards were purchased at convenience,
pharmacy, and grocery stores and registered with Green Dot under stolen identities around the
country. Law enforcement learned that the identities had been stolen through the course of
interviews and review of documents and other records indicating that the individuals ostensibly
applying for benefits had not actually done so.
14.

Law enforcement also learned that, following Hurricane Irma in September 2017

and other federally-certified disasters, about $8 million in FEMA immediate and individual
assistance in amounts of $500.00 per claim was paid to Green Dot debit cards that law
enforcement learned were held by perpetrators of fraud—that is, individuals who applied online
with FEMA for the benefits under the stolen identities of disaster-affected individuals who were
eligible for $500.00.
15.

The ensuing criminal investigation by the DHS OIG, the USSS, and SSA OIG has

uncovered evidence of a fraud and identity theft scheme involving a large network of coconspirators who perpetrated this fraud, with stolen funds from FEMA, the SSA, and the DOL
(among other stolen public funds). The facts underlying this investigation are based on, among
other things, records obtained through subpoenas and voluntary production, interviews of
individuals, internal DHS records, and public records.

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16.

DHS OIG, the USSS, and the SSA OIG have executed multiple search warrants in

the state of Maryland as a result of this investigation, including five residence search warrants.
These residence search warrants were executed on the residences of OKIRIKA, an individual
who will be referred to herein as CO-CONSPIRATOR 1, and three other individuals. These five
individuals were all identified through bank records or surveillance footage as having received
illicit funds from this fraud scheme on Green Dot debit cards.
17.

In that regard, the above-described funds placed onto the Green Dot debit cards

were often subsequently spent, deposited into bank accounts, or "cashed out" through ATM
withdrawals or the purchase of money orders in a variety of areas around the country. Based on
my training and experience, this pattern of transactions involving money orders is indicative of
knowledge of illegal sources of funds, and therefore "layering" transactions in order to help
anonymize them. In my training and experience, such bank account, or "funnel account," activity
is used to launder funds, disguising the funds' illicit source and purpose and helping to redirect it
to other ends, in violation of, for example, 18 U.S.C. § 1956.
18.

Through both personal interviews conducted with suspects and evidence

discovered during the execution of search warrants on other suspects' residences, law
enforcement has learned that in the majority of cases these suspects are in possession of stolen
personal identifying information ("PIT") such as names, SSNs, dates of birth, account numbers,
addresses, phone numbers, and passwords.
19.

Equipped with the stolen PH, the suspects or their co-conspirators purchased

Green Dot debit cards and then registered the cards at GreenDot.com under a variety of stolen
identities, before they received government funds. The co-conspirators have committed wire
fraud in this fraud scheme each time a fraudulent government program application was made
over the internet, as occurred in this case, as well as each time illicit funds were electronically
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deposited onto the Green Dot debit cards from government accounts in response to those
applications, and each time funds were pulled from the Green Dot debit cards for subsequent use
or "laundering."
20.

During the investigation, cards wielded by OKIRIKA—as identified through

video and documentary evidence—were confirmed as having received illicit payments from
FEMA, the SSA, and DOL totaling more than approximately $102,500.00. These funds appeared
on at least nine Green Dot cards purchased from June 24, 2017, through September 27, 2017,
several of which are described below, as examples. The funds stemmed from false claims
submitted to FEMA and the SSA using what law enforcement understands to have been at least
25 stolen identities from March 2017 to October 2017.
Green Dot card ending in x2032
21.

Green Dot card ending in x2032 was purchased at a Dollar Tree in Gloucester

City, New Jersey, on July 3,2017, and was registered under the stolen identity of Victim 1 of
Indiana. There was no apparently licit activity on that card, and then, on September 1, 2017;
September 15, 2017; and October 2, 2017, that card was used to register for $500.00 in FEMA
immediate disaster assistance under three other different stolen identities — Victim 2 of Florida;
Victim 3 of Texas; and Victim 4 of Georgia. Money was paid to the card on behalf of stolen '
identity Victims 3 and 2 on or about September 12, 2017, and September 19,2017, respectively.
Before November 27, 2017, that card was also used to register for SSA benefits totaling
$21,171.50 under another, different stolen identity of Victim 5, which benefits were paid to the
card on or about November 27, 2017.
22.

On September 15, 2017, U.S. Postal Service money order #2386307650-4 for

$483.00 payable to OKIRIKA and deposited into his Bank of America bank account was
purchased using Green Dot card ending in x2032. Then, from November 27, 2017, to November
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30, 2017, at least $18,237.00 was pulled from the card ending in x2032 through six different
Walmart cash centers in Maryland and at least $2,900.00 was pulled from the card at three
different Woodforest National Bank and M&T Bank ATMs.
Green Dot card ending in x7843
23.

Green Dot card ending in x7843 was purchased at a Dollar Tree in Bowie,

Maryland, on July 6, 2017, and was registered under the stolen identity of Victim 6 of California.
There was no apparently licit activity on that card, and then, on August 30, 2017; September 15,
2017, and September 29, 2017, that card was used to register for $500.00 in FEMA immediate
disaster assistance under three other different stolen identities —Victim 7 of Texas; Victim 8 of
Florida; and Victim 9 of Georgia. Money was paid to the card on behalf of stolen identity
Victims 7 and 9 on or about September 5, 2017, and October 3, 2017. Before January 4, 2018,
that card was used to register for SSA benefits totaling $18,617.00 under another, different stolen
identity of Victim 10, which benefits were paid to the card on or about January 4, 2018.
24.

On September 6, 2017, and October 3, 2017, the $1,000.00 in FEMA funds were

pulled from the card ending in x7843 through a Bank of America ATM and small purchases.
Then, from January 5, 2018, to January 8, 2018, at least $14,012.00 was pulled from the Green
Dot card through four different Walmart cash centers in Maryland and Washington, D.C. At least
$2,800.00 was pulled from the card in consecutive transactions at a single Woodforest Bank
ATM in Laurel, Maryland, on January 5,2018, by CO-CONSPIRATOR 1. CO-CONSPIRATOR
1 withdrew at least $12,000.00 of the $14,012.00 from Walmart cash centers in Pasadena,
Severn, Maryland, and Columbia, Maryland on January 5, 2018, and three different Walmart
cash centers in Washington, D.C., on January 8, 2018, as identified in surveillance videos. At
least $1,500.00 in Western Union money orders made out to OKIRIICA were also purchased
using the card, and $200.00 cash back obtained, on January 8, 2018, at around 1:39 p.m. (subject
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to time zone discrepancies), at a Food Lion in Glen Burnie, Maryland, by CO-CONSPIRATOR
1, as identified in a surveillance video. Specifically, CO-CONSPIRATOR 1 purchased three
$500 Western Union money orders with serial numbers 17-703710327; 17-703710328; 17703710329, paid to the order of OKIRIKA; and one $70 Western Union money order, serial'
number 17-703710330, paid to an unknown recipient.
Green Dot card ending in x5822
25.

Green Dot card ending in x5822 was purchased at a Dollar Tree in Capitol

Heights, Maryland, on July 2, 2017, and was registered under the stolen identity of Victim 11 of
California. There was no apparently licit activity on that card, and then on August 29, 2017,
September 14, 2017, September 26, 2017, September 29, 2017, and October 16, 2017, that tard
was used to register for $500.00 in FEMA immediate disaster assistance under five other
different stolen identities. Money was paid to the card on behalf of stolen identity victims Victim
12 of Florida and Victim 13 of Georgia on or about September 25, 2017, and October 2, 2017.
Before December 26, 2017, that card was used to register for SSA benefits totaling $22,223.00
under another, different stolen identity of Victim 14, which benefits were paid to the card on or
about December 26, 2017.
26.

The card was then used by CO-CONSPIRATOR 1, as seen in video stills, to

withdraw funds totaling $2,400.00 in consecutive transactions from a Woodforest Bank ATM in
Severn, Maryland, on December 27, 2017, at approximately 6:30 p.m. The same card was then
used, at approximately 7:30 p.m., to purchase $500 Western Union money orders with serial
numbers 17-708268971 and 17-708268973, totaling $1,000.00, made out to OKIRIKA, at a
Food Lion in Glen Burnie, Maryland.
27.

The same card was then used on December 28, 2017, at approximately 10:02 a.m.

(subject to time zone discrepancies), at a Food Lion in Randallstown, Maryland, by CO9

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CONSPIRATOR 1, as identified in video footage, to obtain $200 cash and purchase three $500
Western Union money orders, with serial numbers 17-262868392; 17-262868393; and 17262868394. The Western Union money order with serial number 17-262868392 was paid to the
order of OKIRIKA with address "11754 SO 3B" on January 23, 2018. DHS OIG identified
OKIRIKA's residence at the time as having a corresponding street number (11754) and
apaitment number (3B). The Western Union money order with serial number 17-262868393 was
paid to the order of CO-CONSPIRATOR 1 into his State Employees Cfedit Union of Maryland
account on March 14, 2018. And the Western Union money order with serial number 17262868394 was paid to the order of OKIRIKA into his Bank of America account.
Green Dot card ending in x3921
28.

Green Dot card ending in x3921 was purchased at a Walmart store on August 6,

2017, and was registered under the stolen identity of Victim 15 of Florida. There was no
apparently licit activity on that card, and then on September 26, 2017, that card was used to
register for $500.00 in FEMA immediate disaster assistance under the same identity. Money was
paid to the card on behalf of Victim 15 on or about September 28, 2017. Later that same day,
OKIRIKA, visually identified by law enforcement in video still images, withdrew $485.50 from
a Woodforest ATM in Laurel, Maryland (the city in which he lived) using Green Dot card
ending in x3921.
Green Dot card ending in x1602
29.

Green Dot card ending in x1602 was similarly used to register for $500.00 in

FEMA immediate disaster assistance under three other different stolen identities. Money was
paid to the card on behalf of stolen identity victims Victim 16 of Texas and Victim 17 of Florida
on or about September 14, 2017, and September 26, 2017. On September 15, 2017, the card was
used to purchase a U.S. Postal Service money order for $483.00 at the U.S. Post Office at 1470
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Baltimore Ave., Unit 111, Laurel, Maryland, that was made out to OKIRIKA.
Other Green Dot cards linked to OKIRIKA
30.

Similar patterns are apparent in the use of other Green Dot debit cards, as well.

For instance, during the time period relevant to this case, Green Dot card ending in x3871
received both $500.00 in FEMA immediate disaster assistance under a stolen identity and
$2,273.00 in SSA payments under a different stolenidentity; thereafter, five Western Union
money orders totaling $2,267.00 were purchased using the card at a Maryland Food Lion, written
to OKIRIKA, and deposited into one of his bank accounts. Other cards that had received FEMA
and/or SSA stolen funds and subsequently were subject to money orders being purchased with
those funds at grocery stores around Maryland, written to OKIRIKA, and deposited into one of
his bank accounts included Green Dot cards ending in x2636, x7464, x1636, x4598, and x8286
(from which at least two money orders were also written to CO-CONSPIRATOR 1 and
deposited into one of his bank accounts).
31.

From July 2017 to March 2018, OKIRIKA maintained a Bank of America

account that appeared only to operate as a funnel account for the receipt of money orders written
with funds from the above Green Dot cards, or to cash out wire transfers received by OKIRIKA
of unknown origin in amounts as high as $10,000.00.
32.

On August 1, 2018, a federal search warrant was executed by law enforcement at

the residence of OKIRIKA on Laurel Walk Drive in Laurel, Maryland. Evidence discovered
during the execution of this search warrant included several financial transaction slips and
Western Union wire receipts.
33.

Law enforcement also interviewed a witness ("WITNESS 1") on or about Angust

22, 2018, who advised that he/she had known OKIRIKA for multiple years. WITNESS 1
reported that he/she had not been in contact with OKIRIKA for some time and was unaware of
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any police activity involving him. WITNESS 1 stated that last year, on multiple occasions,
OKIRIKA gave WITNESS 1 money orders, but WITNESS 1 himself/herself did not use Green
Dot cards. Investigation determined that $1000.00 and $840.00 money orders with sequential
serial numbers 2386307671 and 2386307672 were purchased on September 18, 2017, at the U.S.
Postal Service post office at 14720 Baltimore Ave, Unit 111, Laurel, Maryland. The money order
with serial number 2386307671 was paid to North West Crossing from WITNESS 1 and the
money order with serial number 2386307672 was paid to WITNESS 1 and deposited into a PNC
Bank account on September 21, 2017. DHS OIG determined that the money order with serial
number 2386307672 was purchased by Green Dot card ending in x9949, which contained
$9,797.00 in stolen FEMA and Social Security funds and was recovered from COCONSPIRATOR l's residence during the July 18, 2018, execution of the search warrant.
WITNESS 1 was shown the two money orders and acknowledged that the handwriting and
signatures were his/hers and that OKIRIKA had given WITNESS 1 blank money orders totaling
about $3,000 in order to pay for vehicles that OKIRIKA bought from WITNESS 1. WITNESS 1
did not have records readily available, but recalled that OKIRIKA bought a maroon 2007
Hyundai Santa Fe which he shipped to Nigeria and a 2004 Hyundai Sonata as well. WITNESS 1
recounted that in February 2018, OKIRIKA also purchased a white Toyota Camry from
WITNESS 1. WITNESS 1 sometimes bought vehicles from Manheim auto auctions in
Baltimore, Maryland, and recalled that he/she wrote out some blank money orders to Manheim
that were given to him/her by OKIRIKA in payment.
Wire Fraud and Conspiracy to Commit Wire Fraud
34.

Based on my training and experience, the pattern of transactions described

above—including of individuals such as OKIRIKA making multiple cash withdrawals in a short
period, immediately following stolen funds being paid to a debit card, at multiple locations—is
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indicative of both a wire fraud scheme and the particular co-conspirators' knowledge of illegal
sources of funds. OKIRIKA's conduct is typical of the activities of participants in the abovedescribed fraud scheme. Based upon my training and experience, each such transaction involves
the use of interstate wires, including but not limited to electronic communications to Green Dot
headquarters in Pasadena, California, associated with each transaction from a Green Dot card (all
of which occurred, as relevant to OKIRIKA as described above, in and around Maryland).
Interstate wires were also used in the process of each theft of government funds through the
fraudulent government benefit applications (at least for FEMA, the servers for which are in
Kansas City, Missouri, and Mount Weather, Virginia, while the SSA server is in Woodlawn,
Maryland), and the deposit of money onto the cards from the government by way of the wires
and ACH payments (which similarly would not have occurred in Maryland, due to the location
of the Department of the Treasury branches responsible for such payments), as well as when
funds were deposited into OKIRIKA's bank account(s). (The server for OKIRIKA's known
bank account(s) at Bank of America is located in Charlotte, North Carolina.)
35.

Not only is the behavior of obtaining money orders or withdrawing funds from

the Green Dot debit cards in this manner consistent with other suspects' activities in the fraud
scheme at issue, but also multiple suspects have provided admissions to law enforcement
confirming their activities and involvement in the scheme and the use of money orders to help
launder the stolen funds (which they knew at least came from some form of illegal activity).
Those suspected co-conspirators confirmed that they would "cash out" the money from these
Green Dot cards, which money had been loaded onto the cards by at least one other individual,
and would receive a "cut" or percentage of the funds cashed out, in exchange for their role.
36.

For example, OKIRIKA's conduct appears quite similar to that of suspected CO-

CONSPIRATOR 2. On June 19, 2018, a federal search warrant was executed at CO13

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CONSPIRATOR 2's residence. During the execution of that search warrant, DHS OIG located a
ledger containing the last four numbers of many of the Green Dot cards that law enforcement had
identified as having been used by CO-CONSPIRATOR 2 as part of this same scheme, and what
appeared to be associated PINs. CO-CONSPIRATOR 2 waived his Miranda rights and, upon
questioning, admitted he had laundered as much as $200,000.00 from the Green Dot cards from
2017 to about January 2018. CO-CONSPIRATOR 2 admitted that the ledger contained the last
four numbers of the above Green Dot cards and associated PINs as provided by co-conspirators
who gave him the debit cards in person, and the cards were either in the names of individuals
other than the co-conspirators or did not have a name imprinted on the card. COCONSPIRATOR 2 withdrew the money through ATMs and also through money orders, which
he often deposited in his multiple bank accounts. As CO-CONSPIRATOR 2 reported, COCONSPIRATOR 2 would thereafter keep ten percent of the amount that was on the card and pay
the co-conspirators the rest in cash. CO-CONSPIRATOR 2 claimed that the specifics were not
discussed, but that CO-CONSPIRATOR 2 understood that the funds were stolen from
individuals' bank accounts. The Green Dot cards in the ledger were confirmed by law
enforcement as having received illicit payments from the IRS, FEMA, the SSA, and DOL
totaling over $500,000.00.
37.

Similarly, on July 18, 2018, a federal search warrant was executed at suspected

CO-CONSPIRATOR 3's residence. In the execution of that search warrant, DHS OIG located
more than approximately 690 Green Dot cards, and CO-CONSPIRATOR 3 admitted having
been a part of the scheme outlined above with CO-CONSPIRATOR 2, among other criminal
conduct. CO-CONSPIRATOR 3 as well as CO-CONSPIRATOR 2 had been identified by law
enforcement in the same manner as OKIRIKA had been, through the pattern of transactions they
engaged in using the Green Dot debit cards at issue.
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38.

As mentioned above, OKIRIKA's conduct also appears quite similar to that of

CO-CONSPIRATOR 1, as well, at whose residence on July 18, 2018, a federal search warrant
was executed. Like OKIRIKA, CO-CONSPIRATOR 1 had been identified as having wielded
Green Dot cards containing stolen government funds described above, and had done so until
March 2018. Evidence discovered during the execution of this search warrant included 237
Green Dot debit cards. Of the 237 Green Dot debit cards, 178 had been activated and utilized.
The 178 activated Green Dot debit cards were confirmed by law enforcement to have received
fraudulent benefit payments utilizing stolen identities in the amount of approximately
$653,576.06.
39.

When questioned by law enforcement, CO-CONSPIRATOR 1 claimed that he

had stolen the Green Dot debit cards that law enforcement had discovered in his residence, and
denied involvement in the fraud scheme (and denied even having used any Green Dot debit
cards). However, video evidence possessed by law enforcement directly contradicted that
assertion, as CO-CONSPIRATOR 1 had obtained money orders and cash utilizing Green Dot
debit cards at issue in this case and deposited those funds into his bank accounts. For example, in
December 2017 and January 2018, CO-CONSPIRATOR 1 was observed on surveillance video
making cash withdrawals from Green Dot debit card x1912, and at least six money orders were
procured from that same card made out to CO-CONSPIRATOR 1 and deposited into one of his
bank accounts, which was confirmed at least in part by video surveillance. As another example,
on January 4,2018, and January 5,2018, CO-CONSPIRATOR 1 was observed on surveillance
video utilizing Green Dot debit card x7750 to withdraw approximately $10,583.00 in illicit funds
at four different Walmart cash centers around Maryland and one ATM. The funds on both of
those example cards had been stolen from FEMA and the SSA. Further, when law enforcement
was making entry into CO-CONSPIRATOR l's residence, CO-CONSPIRATOR 1 was
15

 Case 8:18-mj-02452-GLS Document 1-1 Filed 09/07/18 Page 16 of 17

discovered attempting to chew and eat a paper transaction receipt.
40.

Review of the content on CO-CONSPIRATOR l's mobile phone revealed

WhatsApp correspondence between CO-CONSPIRATOR 1 and OKIRIKA from September 14,
2017, to January 8, 2018, in broken English. In the communications, it is unclear who is
directing whom, but CO-CONSPIRATOR 1 and OKIRIKA were clearly referring to buying and
obtaining cash and money orders from Green Dot cards. They included dollar figures and words
such as "Greeno," and referenced Dollar Tree. As recently as June 2018, CO-CONSPIRATOR 1
and OKIRIKA were in contact regarding bank account numbers in association with unspecified
activities.
41.

Based on my training and experience, there are multiple indicators from the above

that show that OKIRIKA has been complicit in violations of 18 U.S.C. §§ 1343 (wire fraud)
and 1349 (conspiracy to commit wire fraud), among other crimes. The Green Dot cards'
funds described above had disparate (all fraudulent) origins, the cards were purchased in
different states, and the cards were first used to withdraw funds on different dates, which
were weeks or months apart. From my training and experience, the patterns are consistent
with the use of prepaid cards by individuals engaged in fraud schemes more generally, too,
in part in order to thwart law enforcement in its efforts to identify and track cards and stolen
funds. The use of Green Dot cards to purchase multiple money orders in the manner seen
here is highly unusual (for people not involved in fraud schemes) and is consistent with
attempts to hide the source of funds and the identities of individuals who have previously
been involved with the funds. Notably, too, individual transaction fees generally accompany
the purchases of money orders and even ATM and other transactions, such that the volume
of transactions, from the same source(s) and to the same destination(s), is consistent with
attempts to conceal the origin of funds derived from fraudulent schemes. Thus, co16

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conspirators in connection with offenses such as those described above often engage in these
activities.
CONCLUSION
42.

Based upon my training, experience, and the facts set forth above, I respectfully

submit that there is probable cause to believe that between on or about June 24, 2017, and on or
about August 1, 2018, OKIRIKA violated or conspired to violate federal criminal statutes,
including 18 U.S.C. §§ 1343 and 1349 (wire fraud and conspiracy to commit wire fraud), as
described herein. Accordingly, I request that the Court issue the requested criminal complaint
and arrest warrant authorizing law enforcement to arrest OKIRIICA for the violations of federal
statutes outlined herein.
Respectfully submitted,

arred T. Medenwald
.1.
Special Agent, United States Secret Service
Subscribed and sworn to before me on this 717 day of September, 2018

ONORABLE GINA L. SIMMS
UNITED STATES MAGISTRATE JUDGE

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