Date: September 15, 2021 Contact: newsroom@ci.irs.gov Pittsburgh, PA — Three residents of Texas have been indicted by a federal grand jury in Pittsburgh on charges of mail and wire fraud conspiracy, money laundering conspiracy, and obstruction of justice, Acting United States Attorney Stephen R. Kaufman announced today. The three-count Indictment, returned on August 25, 2021 and unsealed yesterday, names Charles Simpson of Southlake, Texas, Tanisha Jackson and Paige Jackson both of Lancaster, Texas, as defendants. Charles Simpson and Paige Jackson were arrested yesterday in the Dallas area and will have their initial appearances today in the Northern District of Texas. Tanisha Jackson remains at large. According to the Indictment, Simpson, Tanisha Jackson, and Paige Jackson controlled and operated HOIN, Inc. ("HOIN"), a Texas-based non-profit organization. The defendants allegedly caused HOIN (a/k/a "Helping Others In Need") to enroll as a "sponsor" in two programs funded by the United States Department of Agriculture ("USDA") for the purpose of providing meals to underprivileged youth—the Child and Adult Care Feeding Program ("CACFP") and the Summer Food Service Program ("SFSP") (collectively, "the feeding programs"). CACFP funded after-school meal service during the school year, while SFSP operated in the summer months. In Pennsylvania, the Pennsylvania Department of Education ("PADOE") administered the USDA-funded feeding programs. As alleged, the defendants, each of whom was previously excluded from participating in the feeding programs in other states, caused the submission of false enrollment documentation to PADOE on behalf of HOIN in connection with its participation in CACFP and SFSP between 2015 and 2019. The Indictment alleges that, among other misrepresentations, HOIN's applications to PADOE used aliases for Charles Simpson and Tanisha Jackson as a means to obscure their involvement and falsely certified that none of its principals had been excluded from the feeding programs. The Indictment further alleges that the defendants caused HOIN to submit reimbursement claims for hundreds of thousands of meals that were never served to eligible children by either inflating the number of meals that, in fact, were served or by seeking reimbursements for meals purportedly served on days on which the identified feeding site was not operating at all. To conceal their fraudulent conduct and justify HOIN's claimed meal service, the defendants allegedly submitted fabricated documents to PADOE in connection with periodic program reviews, and on certain occasions Tanisha Jackson impersonated Paige Jackson, her daughter, in interactions with PADOE. In total, PADOE issued reimbursement payments to HOIN in excess of approximately $4 million between 2015 and 2019. The Indictment further alleges that Simpson and Tanisha Jackson engaged in numerous financial transactions involving the proceeds of their alleged fraud. Specifically, Simpson and Tanisha Jackson allegedly spent hundreds of thousands of dollars in HOIN reimbursements on shopping sprees at high-end apparel stores, personal air travel and lodging, and the acquisition of at least nine luxury vehicles, including a Bentley, two Land Rovers, two Maseratis, two Mercedes, a Hummer, and a Porsche. The defendants also allegedly withdrew cash from HOIN bank accounts in excess of $10,000 on more than a dozen occasions. In addition, Simpson is charged with obstruction of justice based on multiple lies he allegedly told federal law enforcement officers during a voluntary interview. "The defendants allegedly created a nonprofit to provide meals to underprivileged children in our area, but instead billed and were reimbursed for services they never provided; they then used those ill-gotten funds for extravagant personal luxury purchases," said Acting U.S. Attorney Kaufman. "Submitting fraudulent claims equals stealing, and those who perpetrate financial fraud against the government will be vigorously prosecuted." USDA Office of Inspector General, Special Agent-in-Charge Bethanne M. Dinkins stated, "The Child and Adult Care Food Program and Summer Food Service Program were created to provide food and nutrition to those who truly need this assistance. Those who are involved in fraud and abuse of USDA feeding programs will be investigated by our office to the fullest extent. Our joint investigation with the Internal Revenue Service, Criminal Investigation and Federal Bureau of Investigation identified those who sought to profit from the CACFP through illegal schemes. The USDA Office of Inspector General will continue to dedicate investigative resources, working with our law enforcement and prosecutorial partners, in order to protect the integrity of these programs and bring to justice those who commit fraud." "It is a crime to knowingly engage in monetary transactions involving criminally derived property of a value greater than $10,000 that is derived from a specified unlawful activity, such as mail fraud or wire fraud," said Yury Kruty, Acting Special Agent in Charge of IRS-Criminal Investigation. "IRS-CI is adept at tracing complex financial transactions and my office is committed to working with our law enforcement partners to help unravel schemes such as this." "It's very disappointing when greed and selfishness take over and deprive our youth of much needed funding to provide them with nutritious meals," said FBI Pittsburgh Special Agent in Charge Mike Nordwall. "To use a non-profit organization as a means to engage in fraud targeting USDA-funded feeding programs is unacceptable. It's also insulting to the teachers and educators working every day to make a better future for our children." All three defendants are charged with conspiracy to commit mail and wire fraud, which imposes a maximum term of imprisonment of twenty years and a fine not more than the greater of $250,000 or an alternative fine in an amount not more than the greater of twice the gross pecuniary gain to any person or twice the pecuniary loss to any person other than the defendant. Simpson and Tanisha Jackson are charged with money laundering conspiracy, which imposes a maximum term of imprisonment of ten years and a fine of not more than $250,000 or an alternative fine of not more than twice the amount of the criminally derived property involved in the transaction. Finally, the obstruction of justice charge as to Simpson imposes a maximum term of imprisonment of ten years and a fine of not more than $250,000. Under the Federal Sentencing Guidelines, the actual sentence imposed would be based upon the seriousness of the offenses and the prior criminal history, if any, of the defendants. Assistant United States Attorneys Eric G. Olshan and Nicole Vasquez Schmitt are prosecuting this case on behalf of the government. The United States Department of Agriculture – Office of Inspector General, The Internal Revenue Service – Criminal Investigation, and the Federal Bureau of Investigation conducted the investigation leading to the Indictment in this case. An Indictment is an accusation. A defendant is presumed innocent unless and until proven guilty.
