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No. 21-13103","","Criminal Complaint filed in the United States District Court for the District of New Jersey against John Jhong, alleging conduct between about April 2020 and October 2020. Attachment A sets out counts for bank fraud, false representation of a social security number, and money laundering by concealing and disguising proceeds of unlawful activity. Attachment B provides an IRS Special Agent overview, describing an alleged scheme to obtain approximately $1.9 million in Paycheck Protection Program funds through fabricated income/tax materials and false certifications. 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No . 21-13103  \nI, Vincent Flynn, being duly sworn, state the following is true and correct to the best of my knowledge and belief.  \nSEE ATTACHMENT A  \nI further state that I am a Special Agent with the Internal Revenue Service and that this Complaint is based on the following facts:  \nSEE ATTACHMENT B  \ncontinued on the attached page and made a part hereof.  \nVincent Flynn, Special Agent  \nInternal Revenue Service  \nAttested to by the affiant in accordance with the requirements of Fed. R. Crim.  \nP. 4.1(b)(2)(A) by telephone .  \nLeda Dunn Wettre /s/  \nHonorable Leda Dunn Wettre United States Magistrate Judge  \nCase 2:21-mj-13103-LDW Document 1 Filed 03/17/21 Page 2 of 10 PageID: 2  \nATTACHMENT A  \nCOUNT ONE  \n(Bank Fraud)  \nBetween in or around April 2020 and in or around October 2020, in the District of New Jersey and elsewhere, the defendant,  \nJOHN JHONG ,  \ndid knowingly and intentionally execute and attempt to execute a scheme and artifice to defraud one or more financial institutions, namely: Lender A, Lender B, Lender C, and Lender D, the deposits of which were insured by the Federal Deposit Insurance Corporation, and to obtain money, funds, credits, assets, securities, and other property owned by and under the custody and control of such financial institutions by means of materially false and fraudulent pretenses, representations, and promises .  \nIn violation of Title 18, United States Code, Section 1344(2) .  \nCase 2:21-mj-13103-LDW Document 1 Filed 03/17/21 Page 3 of 10 PageID: 3  \nCOUNT TWO  \n(False Representation of Social Security Number)  \nBetween in or around April 2020 and in or around October 2020, in the District of New Jersey and elsewhere, the defendant,  \nJOHN JHONG ,  \nwith intent to deceive, did cause the payment of federal funds by falsely representing that a social security number was assigned to oneself or another person when in fact such number was not the social security account number assigned to him or to such other person .  \nIn violation of Title 42, United States Code, Section 408(a)(7)(B) .  \nCase 2:21-mj-13103-LDW Document 1 Filed 03/17/21 Page 4 of 10 PageID: 4  \nCOUNT THREE  \n(Money Laundering-Conceal and Disguise)  \nBetween in or around April 2020 and in or around October 2020, in the District of New Jersey and elsewhere, the defendant,  \nJOHN JHONG ,  \nconducted and attempted to conduct a financial transaction with the proceeds of a specified unlawful activity, namely proceeds from Bank Fraud, in violation of 18 U.S.C. § 1344(2), knowing that the transaction involved the proceeds of unlawful activity and was designed in whole or in part to conceal and disguise the nature, location, source, ownership, and the control of the proceeds of the specified unlawful activity.  \nIn violation of Title 18, United States Code, Section 1956(a)(1)(B)(i) .  \nCase 2:21-mj-13103-LDW Document 1 Filed 03/17/21 Page 5 of 10 PageID: 5  \nATTACHMENT B  \nI, Vincent Flynn, am a Special Agent with the Internal Revenue Service (“IRS*”) . I have participated in this investigation, discussed this matter with other law enforcement officers, and have reviewed documents and other materials. I have knowledge of the following facts . Because this Criminal Complaint is being submitted only for the limited purpose of establishing probable cause, I have not included each and every fact known to me concerning this investigation . I have set forth only the facts which I believe are necessary to establish probable cause. Unless specifically indicated, all conversations and statements described in this affidavit are related in substance and in part and all dates and figures are approximate.  \nOVERVIEW  \n1. Between in or around April 2020 and in or around October 2020, John Jhong (hereinafter “Jhong” or the “def","cbCairnj2DZVYXZP","https://ap.wps.com/l/cbCairnj2DZVYXZP","pdf",272453,10,"English","# UNITED STATES DISTRICT COURT\n## Criminal Complaint\n## Attachment A: Counts One to Three\n## Attachment B: IRS Special Agent Overview\n## Paycheck Protection Program Background","[{\"question\":\"What is this document’s purpose?\",\"answer\":\"It is submitted to establish probable cause for the allegations described in the Criminal Complaint and attachments.\"},{\"question\":\"What claims are listed in Attachment A?\",\"answer\":\"Attachment A includes counts for Bank Fraud, False Representation of a Social Security Number, and Money Laundering-Conceal and Disguise.\"},{\"question\":\"What program funding is referenced in Attachment B?\",\"answer\":\"Attachment B describes an alleged scheme to obtain approximately $1.9 million in Paycheck Protection Program (PPP) funds by submitting false information and certifications.\"}]","CRIMINAL COMPLAINT - Mag. No. 21-13103 | PDF",1789810332]