Santos, George - GJ Charges

Case 2:23-cr-00197-JS Document 1 Filed 05/09/23 Page 1 of 20 PageID #: 1
Fl LED
IN CLERK'S OFFICE
U.S. DISTRICT COURT E.O.N.Y.
RCH:AXB/LZ
F. #2022R0 1030
* MAY 09 2023 *
UNITED STATES DISTRICT COURT LONG ISLAND OFFICE
EASTERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA INDICTMEN'"2s
- against - Cr.No.IR 197

(T. 18, U.S.C., §§ 641, 981(a)(l)(C),
GEORGEANTHONYDEVOLDER 982(a)(l), 982(b)(l), 100l(a)(2),
SANTOS, lO0l{c)(l), 1343, 1957(a), 1957(b), 2
also known as "George Santos," and 3351 et~.; T. 21, U.S.C., § 853(p);
T. 28, U.S.C., § 246l(c)
Defendant.
SEYBER'I;J.
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THE GRAND JURY CHARGES: SHIELDS, M.J.
INTRODUCTION TO ALL COUNTS
At all times relevant to this Indictment, unless otherwise indicated:
I. Relevant Individuals and Entities
1. The defendant GEORGE ANTHONY DEVOLDER SANTOS, also
known as "George Santos," was a resident of Queens and Suffolk Counties. During the 2020
and 2022 election cycles, DEVOLDER SANTOS campaigned as a candidate for the United
States House of Representatives (the "House"). On or about November 8, 2022, DEVOLDER
SANTOS was elected the United States Representative for New York's Third Congressional
District, which covered parts of Queens and Nassau Counties in the Eastern District of New
York. DEVOLDER SANTOS was sworn into office on or about January 7, 2023.
2. The Devolder Organization LLC was a Florida Limited Liability
Company ("LLC") formed on or about May 11, 2021, with its principal place of business in
Melbourne, Florida. The defendant GEORGE ANTHONY DEVOLDER SANTOS was the sole
beneficial owner of the Devolder Organization LLC.
3. Company #1, an entity the identity of which is known to the Grand Jury,
was a Florida LLC formed on or about November 1, 2021, with its principal place of business in
Merritt Island, Florida. At the time of its organization, Company #1 had two authorized
managers, one of which was the Devolder Organization LLC.
4. Person #1, an individual whose identity is known to the Grand Jury, was a
political consultant operating in Queens County and surrounding areas, including areas within
the Eastern District of New York. In and about and between September 2022 and October
2022, at the direction of the defendant GEORGE ANTHONY DEVOLDER SANTOS, Person #1
acted on behalf of Company # 1.
5. Investment Firm #1, an entity the identity of which is known to the Grand
Jury, was a Nevada corporation with its principal place of business in Melbourne, Florida.
Investment Firm # 1 was purportedly engaged in retail sales of securities products. In and about
and between January 2020 and March 31, 2021, the defendant GEORGE ANTHONY
DEVOLDER SANTOS was employed by Investment Firm # 1 as a Regional Director. In that
capacity, DEVOLDER SANTOS received an annual salary of approximately $120,000, which
was deposited into a personal bank account maintained by DEVOLDER SANTOS ("Devolder
Santos Bank Account #1") in regular intervals beginning on or about February 3, 2020 and
continuing through on or about April 15, 2021.
II. Fraudulent Political Contribution Solicitation Scheme
6. In and about and between September and October 2022, the defendant
GEORGE ANTHONY DEVOLDER SANTOS devised and executed a scheme to defraud

supporters of his candidacy for the House and to obtain money from them by fraudulently
inducing supporters to contribute funds to Company # 1 under the false pretense that the money
would be used to support DEVOLDER SANTOS's candidacy and then actually spending
thousands of dollars of the solicited funds on personal expenses, including luxury designer
clothing and credit card payments. DEVOLDER SANTOS communicated and directed Person
#1 to communicate to those supporters false information about Company #1, including: that
Company # 1 was a Section 501 (c)(4) social welfare organization or an independent expenditure
committee and that contributions made to Company # 1 would be used on independent
expenditures in support ofDEVOLDER SANTOS's candidacy during the 2022 election cycle.
In actuality, as explained below, Company #1 was neither a Section 501(c)(4) social welfare
organization nor an independent expenditure committee, and upon receipt of contributions by
those supporters to Company #1, DEVOLDER SANTOS converted most of those funds to his
own personal benefit.
A. Applicable Campaign Finance Laws
7. The Federal Election Campaign Act of 1971, as amended, Title 52, United
States Code, Sections 30101, et seq. ("FECA"), limited financial influence in the election of
candidates for federal office and provided for public disclosure of the financing of federal
election campaigns. FECA limited the amount and sources of money that could be contributed
to a federal candidate or that candidate's authorized campaign committee and political
committees established and maintained by a national political party. In particular, while
candidates for federal office were permitted to give or loan their own campaigns unlimited sums
of money, for the 2022 election cycle, other individuals were limited to contributing $2,900 per
election per candidate committee. FECA expressly provided that contributions made through an
intennediary were treated as contributions from the original source.
8. An independent expenditure-only committee, or "Super PAC," was a type
of political committee that could accept unlimited contributions and make unlimited
expenditures independent of a candidate or campaign. Super PACs were prohibited from
making contributions to candidates in the form of coordinated expenditures. Super PACs were
required to register with the FEC within IO days of receiving contributions or making
expenditures aggregating more than $1,000 during a calendar year. The defendant GEORGE
ANTHONY DEVOLDER SANTOS knew that Company #1 was not, in fact, registered with the
FEC as a Super PAC.
9. Section 50l(c)(4) of the Internal Revenue Code related to tax-exempt
social welfare organizations. The defendant GEORGE ANTHONY DEVOLDER SANTOS
knew that Company # 1 was not, in fact, registered with the Internal Revenue Service as a Section
50l(c)(4) social welfare organization.
B. Defendant's Fraud Scheme
10. As part of the scheme to defraud, the defendant GEORGE ANTHONY
DEVOLDER SANTOS directed Person #1 to solicit contributions to Company #1 from
prospective contributors via emails, text messages and telephone calls. In furtherance of those
efforts, DEVOLDER SANTOS arranged for the creation of an email address associated with
Company #1 for Person #1, provided Person #1 with the names and contact information of
prospective contributors and conveyed false information to Person # 1 about the nature of
Company # 1 and the purpose of the contributions, knowing that Person # 1 would then
communicate the false information to prospective contributors.

I I. At the direction of the defendant GEORGE ANTHONY DEVOLDER
SANTOS, Person # 1 falsely advised prospective contributors, inter alia, that Company # 1 was a
Section 501(c)(4) social welfare organization or an independent expenditure committee and
therefore not subject to contribution limits, and that contributions to Company # 1 would be spent
on television advertisements and other independent expenditures benefitting DEVOLDER
SANTOS's candidacy for the House. At the direction ofDEVOLDER SANTOS, Person #1
also provided prospective contributors with instructions for wiring funds to a bank account
maintained by Company #1, as to which DEVOLDER SANTOS was an authorized signatory
("Company # I Bank Account").
12. It was further a part of the scheme to defraud that the defendant GEORGE
ANTHONY DEVOLDER SANTOS sent to prospective contributors one or more text messages
in which he requested that those prospective contributors speak with representatives of Company
# 1, indicated that he needed contributions to Company # 1 and falsely represented that such
contributions would be spent on television advertisements independently purchased by Company
#1 in support of DEVOLDER SANTOS's candidacy for the House.
13. After receiving emails and text messages from the defendant GEORGE
ANTHONY DEVOLDER SANTOS and Person #1, and in reliance upon the materially false
statements therein, one or more individuals made contributions to Company # I in sums
exceeding the limits pertaining to candidate committees.
14. On or about September 12, 2022, DEVOLDER SANTOS falsely advised
Person #1 via text message that Company #1 was "a small C4" that existed "just to help this
race" and that there were "no limits" with respect to contributions.
15. On or about October 4, 2022, Person #1, acting at the direction of the
defendant GEORGE ANTHONY DEVOLDER SANTOS and on behalf of Company #1, sent an
email to Contributor # 1, an individual whose identity is known to the Grand Jury. That email
falsely stated, inter alia, that Company #1 was attempting to "raise another $700,000 dollars to
reach our goal of$1.5 million to invest in [DEVOLDER SANTOS's] race" to compete with the
money "independently" raised for DEVOLDER SANTOS's opponent. Thereafter, on or about
October 20, 2022, Person #1, again acting at the direction ofDEVOLDER SANTOS and on
behalf of Company # 1, sent to Contributor # 1 another email, which falsely stated that a
contribution from Contributor # 1 would be spent, at least in part, "to get our advertising up on
TV." On or about October 25, 2022, Person #1, again acting at the direction ofDEVOLDER
SANTOS and on behalf of Company # 1, sent to Contributor # 1 a text message, which again
falsely stated that a contribution from Contributor # 1 would be spent, at least in part, "to
purchase ads supporting George Santos." On or about October 26, 2022, in reliance upon these
emails and text message, Contributor #1 caused the sum of $25,000 to be wired to Company #1.
16. In addition, on or about October 12, 2022, Person # l, acting at the
direction of the defendant GEORGE ANTHONY DEVOLDER SANTOS and on behalf of
Company # 1, sent an email to Contributor #2, an individual whose identity is known to the
Grand Jury. That email falsely stated, inter alia, that Company # 1 was formed "exclusively" to
aid in electing DEVOLDER SANTOS and that "[t]here are no limits for contributors as we are a
501 c4 Independent Expenditure committee under federal campaign finance law and do not
coordinate directly with the Santos campaign." The email to Contributor #2 further stated that
all funds raised by Company #1 would be spent "directly on supporting George and his election."
Further, the email to Contributor #2 contained an attachment, which DEVOLDER SANTOS had
previously approved. That attachment described Company # 1 as having been "created for this
singular purpose, to support that candidate, George Santos" and represented that Company # 1
was "fully committed to dedicating all its resources to making sure that George Santos is the next
member of Congress representing NY-03." On or about October 21, 2022, DEVOLDER
SANTOS sent to Contributor #2 one or more text messages in which DEVOLDER SANTOS
reiterated the need for contributions to Company # 1, which he falsely stated would be spent "on
TV'' advertisements. That same day, in reliance upon the email and accompanying text
messages, Contributor #2 caused the sum of $25,000 to be wired to Company #1.
17. Shortly after the contributions from Contributor # 1 and Contributor #2
were received by Company #I in the Company #1 Bank Account, they were transferred into
bank accounts controlled by the defendant GEORGE ANTHONY DEVOLDER SANTOS,
including the Devolder Santos Bank Account # I and a second personal bank account maintained
by DEVOLDER SANTOS ("Devolder Santos Bank Account #2"). From there, the funds
received from Contributor #1 and Contributor #2 were spent by DEVOLDER SANTOS for his
personal benefit, including to make cash withdrawals, personal purchases of luxury designer
clothing, credit card payments, a car payment, payments on personal debts, and one or more
bank transfers to DEVOLDER SANTOS's personal associates. Thus, contrary to
representations made by DEVOLDER SANTOS and Person# I, who was acting at the direction
ofDEVOLDER SANTOS, these contributions to Company #1 were not spent on television
advertisements or other independent expenditures in support ofDEVOLDER SANTOS's
candidacy for the House.

III. Fraudulent Application for and Receipt of Unemployment Benefits
18. On or about March 27, 2020, the Coronavirus Aid, Relief, and Economic
Security ("CARES") Act was enacted. In light of the ongoing health crisis related to the novel
coronavirus, COVID-19, the CARES Act allocated additional unemployment benefits for
eligible individuals. Specifically, the CARES Act established additional unemployment
insurance programs, including the Pandemic Unemployment Assistance program and the Federal
Pandemic Unemployment Compensation program. Both programs were federally funded and
were administered by states, including New York State. Funds from both programs, as well as
from the Federal Emergency Management Agency's Lost Wages Assistance Program, comprised
the benefits fraudulently obtained by the defendant GEORGE ANTHONY DEVOLDER
SANTOS in connection with the scheme outlined below.
19. On or about June 17, 2020, the ~efendant GEORGE ANTHONY
DEVOLDER SANTOS applied to receive unemployment insurance benefits through the New
York State Department of Labor ("NYS DOL''). In that application, DEVOLDER SANTOS
falsely claimed to have been unemployed since the week of March 22, 2020. Beginning on or
about June 19, 2020, and continuing through on or about April 15, 2021, DEVOLDER SANTOS
certified his continuing eligibility for unemployment benefits on a weekly basis, in each case
falsely attesting, inter ali~ that he was unemployed, available to take on new work, and eligible
for benefits. In truth and in fact, however, beginning on or about February 3, 2020, and
continuing through on or about April 15, 2021, DEVOLDER SANTOS was a Regional Director
at Investment Firm # 1. During that period, with the exception of on or about and between July
5, 2020 and August 30, 2020, DEVOLDER SANTOS received regular deposits into his personal
bank accounts as part of his Regional Director salary of approximately $120,000 per year.
20. For the period of on or about and between March 22, 2020 and April 15,
2021, based on a false application and false weekly certifications to the NYS DOL, the defendant
GEORGE ANTHONY DEVOLDER SANTOS received approximately $24,744 in
unemployment insurance benefits, which were deposited into Devolder Santos Bank Account #2.
The benefits received by DEVOLDER SANTOS were fully funded by the United States and a
department and agency thereof, to wit: the United States Department of the Treasury.
IV. False Statements in House Disclosure Reports
21. Pursuant to the Ethics in Government Act of 1978, as a candidate for the
House in 2020 and 2022, the defendant GEORGE ANTHONY DEVOLDER SANTOS had a
legal duty to file a Financial Disclosure Statement ("House Disclosures") at designated times
prior to each of the general elections held on November 3, 2020 and November 8, 2022,
respectively. In each of those House Disclosures, DEVOLDER SANTOS was required to make
a "full and complete statement" disclosing, inter alia: (a) his assets and income, transactions,
liabilities, positions held and arrangements and agreements; (b) "the source, type, and amount or
value of income ... from any source (other than from current employment by the United States
Government)"; and (c) "the source, date, and amount of honoraria from any source, received" for
"the year of filing and the preceding calendar year." As a candidate, DEVOLDER SANTOS
was personally required to certify the House Disclosures were "true, complete, and correct to the
best of my knowledge and belief." The Instruction Guide for Financial Disclosure Statements
published by the U.S. House of Representatives Committee on Ethics provided that there were
civil and criminal penalties for knowingly and willfully falsifying a financial disclosure
statement and cited to Title 18, United States Code, Section 1001.
22. The defendant GEORGE ANTHONY DEVOLDER SANTOS was
required to make these House Disclosures via an online filing system maintained by the House
Committee on Ethics or pre-printed form, and to certify that the statements made therein were
true, complete and correct. DEVOLDER SANTOS was required to file the House Disclosures
with the Clerk of the House, for transmission to the House Committee on Ethics.
23. On or about May 11, 2020, in connection with the 2020 election for the
House, the defendant GEORGE ANTHONY DEVOLDER SANTOS filed two House
Disclosures (the "2020 House Disclosures"), in which he falsely certified that, during the
reporting period: (a) his only earned income consisted of salary, commission and bonuses
totaling $55,000 from Company #2, an entity the identity of which is known to the Grand Jury;
and (b) the only compensation exceeding $5,000 he received from a single source in which he
had an ownership interest was an unspecified commission bonus from Company #2.
24. Contrary to these attestations, however, as the defendant GEORGE
ANTHONY DEVOLDER SANTOS then and there well knew and believed, from approximately
February 1, 2020 through the date upon which he filed the 2020 House Disclosures,
DEVOLDER SANTOS received approximately $25,403 in income from Investment Firm #1,
which he failed to truthfully report as required. Further, DEVOLDER SANTOS knew that he
had received only $27,555 in compensation from Company #2 in 2019.
25. Thereafter, on or about September 6, 2022, in connection with the 2022
election for the House, the defendant GEORGE ANTHONY DEVOLDER SANTOS filed a
House Disclosure (the "2022 House Disclosure"), in which he falsely certified that, during the
reporting period: (a) his earned income consisted of $750,000 in salary from the Devolder
Organization LLC; (b) his unearned income included dividends from the Devolder Organization
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LLC valued at between $1,000,001 and $5,000,000; (c) he had no compensation exceeding
$5,000 from a single source in which he had an ownership interest; (d) he owned a checking
account with deposits totaling between $100,001 and $250,000; and (e) he owned a savings
account with deposits totaling between $1,000,001 and $5,000,000.
26. Contrary to these attestat~ons, as the defendant GEORGE ANTHONY
DEVOLDER SANTOS then and there well knew and believed, during the applicable reporting
period, he had not received from the Devolder Organization LLC the reported amounts of salary
or dividends and, during the reporting period, he did not maintain checking or savings accounts
with deposits in the reported amounts. In addition, from approximately January 2021 through
September 2021, DEVOLDER SANTOS received approximately $28,107 in income from
Investment Firm # 1 and approximately $20,304 in unemployment insurance benefits from the
NYS DOL, both of which he failed to truthfully report as required.
COUNTS ONE THROUGH FIVE

(Wire Fraud - Fraudulent Political Contribution Solicitation Scheme)
27. The allegations contained in paragraphs one through 26 are realleged and
incorporated as if fully set forth in this paragraph.
28. In or about and between September 2022 and October 2022, both dates
being approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendant GEORGE ANTHONY DEVOLDER SANTOS, also known as "George Santos,"
together with others, did knowingly and intentionally devise a scheme and artifice to defraud and
to obtain money by means of one or more materially false and fraudulent pretenses,
representations and promises.
29. On or about the dates set forth below, for the purpose of executing such
scheme and artifice, and attempting to do so, the defendant GEORGE ANTHONY DEVOLDER
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SANTOS, also known as "George Santos," did transmit and cause to be transmitted, by means of
wire communication in interstate and foreign commerce, one or more writings, signs, signals,
pictures and sounds, as set forth below:
Count A1mroximate Description

Date
ONE October 4, 2022 Email on behalf of Company # 1 to Contributor # I falsely

stating that funds received from Contributor # 1 would be
used in support of DEVOLDER SANTOS's candidacy
for the House.
TWO October 12, 2022 Email on behalf of Company # 1 to Contributor #2 falsely

stating that funds received from Contributor #2 would be
used to independently support DEVOLDER SANTOS's
candidacy for the House and that Company # 1 was a
Section 50l(c)(4) social welfare organization that could
accept limitless contributions.
THREE October 20, 2022 Email on behalf of Company # 1 to Contributor # 1 falsely

stating that funds received from Contributor #1 would be
used, in part, to purchase television advertisements
supporting DEV OLDER SANTOS 's candidacy for the
House.
FOUR October 21, 2022 Text message from DEVOLDER SANTOS to

Contributor #2 falsely stating that funds received from
Contributor #2 would be used, in part, to purchase
television advertisements supporting DEVOLDER
SANTOS's candidacy for the House.
FIVE October 25, 2022 Text message on behalf of Company # 1 to Contributor

# l falsely stating that funds received from Contributor # 1
would be used, in part, to purchase television
advertisements supporting DEVOLDER SANTOS's
candidacy for the House.
(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)
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COUNTS SIX THROUGH EIGHT

(Unlawful Monetary Transactions Over $10,000)
31. On or about and between October 21, 2022 and October 26, 2022, both
dates being approximate and inclusive, within the Eastern District of New York and elsewhere,
the defendant GEORGE ANTHONY DEVOLDER SANTOS, also known as "George Santos,"
together with others, did knowingly and intentionally engage in one or more monetary
transactions, in and affecting interstate commerce, in criminally derived property that was of a
value greater than $10,000, as set forth in the chart below, and that was derived from specified
unlawful activity, to wit: wire fraud, in violation of Title 18, United States Code, Section 1343,
contrary to Title 18, United States Code, Section l 957(a):
AnJ!roximate Descri(!tion
Count
Date
SIX October 21, 2022 On or about October 21, 2022, DEVOLDER SANTOS
electronically transferred approximately $25,000
fraudulently obtained from Contributor #2 from Company
#1 Bank Account to Devolder Santos Bank Account #1.
SEVEN October 26, 2022 On or about October 26, 2022, DEVOLDER SANTOS
fraudulently obtained from Contributor # 1 from Company
#1 Bank Account to Devolder Santos Bank Account #2.
EIGHT October 26, 2022 On or about October 26, 2022, DEVOLDER SANTOS
fraudulently obtained from Contributor # 1 from Devolder
Santos Bank Account #2 to Devolder Santos Bank
Account#!.
(Title 18, United States Code, Sections 1957(a), 1957(b), 2 and 3551 et~.)
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COUNTNINE
(Theft of Public Money)
33. In or about and between June 2020 and April 2021, both dates being
approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant
GEORGE ANTHONY DEVOLDER SANTOS, also known as "George Santos," did knowingly,
willfully and without lawful authority embezzle, steal, purloin and convert to his own use money
and things of value of the United States and a department and agency thereof, to wit: money of
the United States Department of the Treasury, the aggregate value of which exceeded $1,000.
(Title 18, United States Code, Sections 641 and 3551 et seq.)
COUNTS TEN AND ELEVEN

(Wire Fraud-Fraudulent Application for and Receipt of Unemployment Benefits)
35. On or about and between June 19, 2020 and April 15, 2021, both dates
being approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendant GEORGE ANTHONY DEVOLDER SANTOS, also known as "George Santos," did
knowingly and intentionally devise a scheme and artifice to defraud the NYS DOL, and to obtain
money from the NYS DOL by means of one or more materially false and fraudulent pretenses,
representations and promises.
36. On or about the dates set forth below, for the purpose of executing the
scheme, and attempting to do so, the defendant GEORGE ANTHONY DEVOLDER SANTOS,
also known as "George Santos," did transmit and cause to be transmitted, by means of wire
15
communications in interstate and foreign commerce, writings, signs, signals, pictures and
sounds, as set forth below:
Count Date Descriution
TEN January 19, 2021 On or about January 19, 2021, DEVOLDER SANTOS
received $564.00 through interstate wires from the NYS
DOL in New York to Devolder Santos Bank Account #2
in New York, passing through one or more computer
servers located outside New York.
ELEVEN January 26, 2021 On or about January 26, 2021, DEVOLDER SANTOS
received $564.00 through interstate wires from the NYS
DOL in New York to Devolder Santos Bank Account #2
in New York, passing through one or more computer
servers located outside New York.
(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)
COUNT TWELVE
(False Statements - 2020 House Disclosure Reports)
38. On or about May 11, 2020, within the Eastern District of New York and
elsewhere, the defendant GEORGE ANTHONY DEVOLDER SANTOS, also known as "George
Santos," in a matter within the jurisdiction of the legislative branch of the Government of the
United States, did knowingly and willfully make one or more materially false, fictious and
fraudulent statements and representations, to wit: DEVOLDER SANTOS submitted to the Clerk
of the House, for delivery to the House Committee on Ethics, an amended House Disclosure
falsely stating that, during the applicable reporting period: (a) his only earned income consisted
of a salary, commission and bonus totaling $55,000 from Company #2; and (b) the only
compensation exceeding $5,000 he received from a single source in which he had an ownership
interest was a commission bonus from Company #2, when in truth and in fact, as DEVOLDER
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SANTOS then and there well knew and believed, he had earned $27,555 from Company #2 in
2019 and had received approximately $25,403 in income from Investment Firm #1 during the
same reporting period, which he failed to report as required.
(Title 18, United States Code, Sections 100l(a)(2), (c)(l) and 3551 et seq.)
COUNT THIRTEEN
(False Statements - 2022 House Disclosure Report)
40. On or about September 6, 2022, within the Eastern District of New York
and elsewhere, the defendant GEORGE ANTHONY DEVOLDER SANTOS, also known as
"George Santos," in a matter within the legislative branch of the Government of the United
States, did knowingly and willfully make one or more materially false, fictious and fraudulent
statements and representations, to wit: DEVOLDER SANTOS submitted to the Clerk of the
House, for delivery to the House Committee on Ethics, a House Disclosure falsely stating that, in
the year 2021 and in 2022 up to the filing date: (a) his earned income consisted of $750,000 in
salary from the Devolder Organization LLC; (b) his unearned income included dividends from
the Devolder Organization LLC valued at between $1,000,001 and $5,000,000; and (c) he had no
compensation exceeding $5,000 from a single source in which he had an ownership interest.
Further, DEVOLDER SANTOS falsely stated that (d) he owned a checking account with
deposits totaling between $100,001 and $250,000; and (e) he owned a savings account with
deposits totaling between $1,000,001 and $5,000,000. Contrary to these statements, in truth and
in fact, as DEVOLDER SANTOS then and there well knew and believed, he had not received
from the Devolder Organization LLC the reported amounts of salary or dividends; he did not
maintain checking or savings accounts with deposits in the reported amounts; and he received
17
approximately $28,107 in income from Investment Firm # 1 and approximately $20,304 in
unemployment insurance benefits from the NYS DOL during the same reporting period, all of
which he failed to report as required.
(Title 18, United States Code, Sections 100l(a)(2), (c)(l) and 3551 et seq.)
CRIMINAL FORFEITURE ALLEGATION

AS TO COUNTS ONE THROUGH FIVE AND NINE THROUGH ELEVEN
41. The United States hereby gives notice to the defendant that, upon his
conviction of any of the offenses charged in Counts One, Two, Three, Four, Five, Nine, Ten and
Eleven, the government will seek forfeiture in accordance with Title 18, United States Code,
Section 98l{a)(l)(C) and Title 28, United States Code, Section 2461(c), which require any
person convicted of such offenses to forfeit any property, real or personal, constituting, or
derived from, proceeds obtained directly or indirectly as a result of such offenses.
42. If any of the above-described forfeitable property, as a result of any act or
omission of the defendant:
(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 divided
without difficulty;
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it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of the defendant up to the value of the forfeitable property
described in this forfeiture allegation.
(Title 18, United States Code, Section 981(a)(l)(C); Title 21, United States Code,
Section 853(p); Title 28, United States Code, Section 246l(c))
CRIMINAL FORFEITURE ALLEGATION

AS TO COUNTS SIX THROUGH EIGHT
43. The United States hereby gives notice to the defendant that, upon his
conviction of any of the offenses charged in Counts Six through Eight, the government will seek
forfeiture in accordance with Title 18, United States Code, Section 982(a)(l), which requires any
person convicted of such offenses to forfeit any property, real or personal, involved in such
offenses, or any property traceable to such property.
44. If any of the above-described forfeitable property, as a result of any act or
omission of the defendant:
(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 divided
without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as
incorporated by Title 18, United States Code, Section 982(b)( 1), to seek forfeiture of any other
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propffflY of the defendant up to the value of the forfeitable property described in this tbrfeiture
aJ\~gation.
(Title J8, United Stat.es Code, Sections 982(a)(l) and 982lb)0); Tide 21, United
States Code, ~tion 853(p))
ATR'U"EBlLL
ONPEACE~-
t , . TED STATES ATfORNEY
EASTERN DISTRICT OF NEW YORK
~~~D1o~~
CH.TEF, PUDLlC INTEGRITY SECTION
U.S. DEPARTh1ENTOF .TTJSTICE
r.w: 2un~1ir.w
FOR.M OJ3D·.l4 No.
JUN.l'l
UNITED STA'fES DJ STRICT COURT

HA.STERN Di3trict of NEW YORK
CRllVHNAL Dl"\'1SION
-~-------...-__..,...__ • I - w --"~"~ - - - - - - -
THE UNITED STATES OF AMERICA

vs.
GEORGE AN"OiO:NY DEVOLDER SANTO~.
-~-----------------._
INDICTMENT
__ _ Defendant.
(T. 18~ U.S.C., §§ 641.. 98l(a)(I )(C),. 982(a)( 1), 98'2(b)(l), 1001La){2),
1343, 1957(a), 1957(b), 2 :and 3351 et g.: T. 21 ll.S.C., § 853(p): T. 28,
___ _ __ _ _ _ U.S.C., !2461(c~
/"
fifeJ mope11comt ti.is___________ __ _ ___ duy
u/ ____________ ,LI). 20 ____ _
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-------------------------------
.RJ·a1t C. l!arris IL1111,w Zl1ckerwl~. Assistant lf.S. Attom.eys (718) 254-U89 I 62fJ4'
AnJll<.Jny Bll/;ntu,la ,iS.'fisttl1" U.S. Afl.cr11ey (631) 7[.'J-7849
Jol.ee Po,in I Jt1ctJb· R. Stcllter, TriulA.ttor,w:;w ()01) SU-1412

Santos, George - GJ Charges

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Case 2:23-cr-00197-JS Document 1 Filed 05/09/23 Page 1 of 20 PageID #: 1

- against - Cr.No.IR 197

At all times relevant to this Indictment, unless otherwise indicated:

I. Relevant Individuals and Entities

1. The defendant GEORGE ANTHONY DEVOLDER SANTOS, also

States House of Representatives (the "House"). On or about November 8, 2022, DEVOLDER

2. The Devolder Organization LLC was a Florida Limited Liability

beneficial owner of the Devolder Organization LLC.

managers, one of which was the Devolder Organization LLC.

acted on behalf of Company # 1.

DEVOLDER SANTOS was employed by Investment Firm # 1 as a Regional Director. In that

capacity, DEVOLDER SANTOS received an annual salary of approximately $120,000, which

continuing through on or about April 15, 2021.

II. Fraudulent Political Contribution Solicitation Scheme

GEORGE ANTHONY DEVOLDER SANTOS devised and executed a scheme to defraud

committee and that contributions made to Company # 1 would be used on independent

organization nor an independent expenditure committee, and upon receipt of contributions by

own personal benefit.

A. Applicable Campaign Finance Laws

to a federal candidate or that candidate's authorized campaign committee and political

committees established and maintained by a national political party. In particular, while

intennediary were treated as contributions from the original source.

8. An independent expenditure-only committee, or "Super PAC," was a type

expenditures independent of a candidate or campaign. Super PACs were prohibited from

FEC as a Super PAC.

9. Section 50l(c)(4) of the Internal Revenue Code related to tax-exempt

social welfare organizations. The defendant GEORGE ANTHONY DEVOLDER SANTOS

50l(c)(4) social welfare organization.

B. Defendant's Fraud Scheme

10. As part of the scheme to defraud, the defendant GEORGE ANTHONY

DEVOLDER SANTOS directed Person #1 to solicit contributions to Company #1 from

communicate the false information to prospective contributors.

I I. At the direction of the defendant GEORGE ANTHONY DEVOLDER

Section 501(c)(4) social welfare organization or an independent expenditure committee and

on television advertisements and other independent expenditures benefitting DEVOLDER

maintained by Company #1, as to which DEVOLDER SANTOS was an authorized signatory

("Company # I Bank Account").

contributions would be spent on television advertisements independently purchased by Company

#1 in support of DEVOLDER SANTOS's candidacy for the House.

statements therein, one or more individuals made contributions to Company # I in sums

exceeding the limits pertaining to candidate committees.

14. On or about September 12, 2022, DEVOLDER SANTOS falsely advised

money "independently" raised for DEVOLDER SANTOS's opponent. Thereafter, on or about

16. In addition, on or about October 12, 2022, Person # l, acting at the

direction of the defendant GEORGE ANTHONY DEVOLDER SANTOS and on behalf of

member of Congress representing NY-03." On or about October 21, 2022, DEVOLDER

messages, Contributor #2 caused the sum of $25,000 to be wired to Company #1.

17. Shortly after the contributions from Contributor # 1 and Contributor #2

bank accounts controlled by the defendant GEORGE ANTHONY DEVOLDER SANTOS,

bank transfers to DEVOLDER SANTOS's personal associates. Thus, contrary to

ofDEVOLDER SANTOS, these contributions to Company #1 were not spent on television

advertisements or other independent expenditures in support ofDEVOLDER SANTOS's

candidacy for the House.

III. Fraudulent Application for and Receipt of Unemployment Benefits

eligible individuals. Specifically, the CARES Act established additional unemployment

the benefits fraudulently obtained by the defendant GEORGE ANTHONY DEVOLDER

SANTOS in connection with the scheme outlined below.

19. On or about June 17, 2020, the ~efendant GEORGE ANTHONY

GEORGE ANTHONY DEVOLDER SANTOS received approximately $24,744 in

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