Date: April 27, 2020 Contact: email@example.com A criminal complaint was unsealed today in federal court in Brooklyn charging Donald Allen and Manuel Revolorio with conspiracy to commit wire fraud by seeking more than $4 million from a purported purchaser of personal protective equipment ("PPE") that the defendants did not own nor otherwise have authorization to sell. The defendants were arrested today in California, and their initial appearance is scheduled for this afternoon before United States Magistrate Judge Pedro V. Castillo in federal court in Los Angeles. Jonathan D. Larsen, Special Agent-in-Charge, Internal Revenue Service Criminal Investigation, New York Field Office (IRS-CI), announced the charges. According to court filings, as part of their fraudulent scheme, Allen and Revolorio misrepresented the nature of their business experience, their inventory of PPE and their right to resell PPE to purported purchasers of PPE. For example, the defendants created a website for their company, International Commerce and Investment Group (ICIG), falsely representing that since 2014 ICIG had worked closely with global traders, medical institutions and other companies to supply PPE. The defendants also falsely claimed that ICIG had contracts and agreements in place to resell millions of masks, and attempted to pressure a potential purchaser to wire more than $4 million to secure those masks. To reinforce their claim to have large supplies of PPE available for sale, the defendants displayed sealed and shrink-wrapped empty boxes at their office, which they represented were filled with masks. The defendants also displayed to an individual, posing as a representative of an investor, more than one million masks that were owned by an unrelated third party – unbeknownst to the defendants, the "representative" was actually a federal law enforcement agent. "At a time when we should be coming together to help one another and support our healthcare professionals who are working heroically to save lives, Donald Allen and Manuel Revolorio allegedly decided to take advantage of the Covid-19 pandemic for their own personal benefit," stated IRS-CI Special Agent-in-Charge Larsen. "IRS-CI is committed to not only protecting the tax system, but also protecting all taxpayers from unscrupulous individuals who attempt to take advantage of them." "The defendants in this case allegedly created an elaborate scam to defraud their victim, going as far as to wrap and label empty boxes and try to pass them off as containing actual personal protective equipment," stated COVID-19 Hoarding and Price Gouging Task Force head Carpenito. "The public should be on guard against these types of schemes, and the perpetrators of them should know that the Department of Justice and its partners are working all the time to disrupt their attempts to prey on the public." "The alleged behavior here is nothing short of a betrayal of fellow citizens – both those serving on the front lines, and the communities who need those essential workers able to safely serve," stated FBI Assistant Director-in-Charge Sweeney. "At this critical time, Allen and Revolorio allegedly deceived potential investors and purchasers into thinking they were running a legitimate business with resell rights to more than three million of these highly sought-after items. The FBI will continuously work to identify and hold accountable any company, individual, or entity whose intention it is to unlawfully take advantage of the current pandemic." "As alleged in the complaint, the defendants sought to take advantage of the urgent national need for life-saving personal protective equipment through a fraudulent scheme designed to line their own pockets," stated United States Attorney Donoghue. "This Office, together with the Department's COVID-19 Hoarding and Price Gouging Task Force, is working tirelessly to ensure that scam artists who seek to capitalize on the worldwide pandemic will be brought to justice." Mr. Donoghue expressed his grateful appreciation to the United States Attorney's Offices in New Jersey and the Central District of California, and the Los Angeles Field Offices of the FBI and IRS-CI for their invaluable assistance in this case. The charge in the complaint is an allegation, and the defendants are presumed innocent unless and until proven guilty. Please report COVID-19 fraud, hoarding or price-gouging to the National Center for Disaster Fraud's National Hotline at 866-720-5721, or email: firstname.lastname@example.org. The government's case is being handled by the Office's Public Integrity and Business & Securities Fraud Sections. Assistant United States Attorneys Nathan Reilly and Hiral Mehta are in charge of the prosecution.