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Monday, September 15, 2025

Criminal – Wire fraud – PPP loan applications - Massachusetts Lawyers Weekly

Where a defendant was convicted of wire fraud and making false statements to a financial institution, those two convictions should be upheld based on evidence that the defendant filed fraudulent applications for multiple Paycheck Protection Program loans for his startup company at the beginning of the COVID-19 pandemic.

“Defendant-Appellant Elijah Majak Buoi (‘Buoi’) applied for multiple Paycheck Protection Program (‘PPP’) loans for his startup company, Sosuda Tech LLC (‘Sosuda’), at the beginning of the COVID-19 pandemic. The Government investigated and charged Buoi for devising a scheme to defraud and obtain PPP funds by filing fraudulent PPP loan applications, and he was ultimately indicted on four counts of wire fraud, in violation of 18 U.S.C. §1343, and one count of making false statements to a financial institution, in violation of 18 U.S.C. §1014. At trial, Buoi moved for judgment of acquittal at the close of the Government’s case on the grounds that the Government provided insufficient evidence to prove beyond a reasonable doubt that he intended to defraud or influence a financial institution. The district court denied the motion. Buoi renewed the motion at the close of his case, resulting in another denial. Buoi was subsequently convicted on all five counts. Boui appeals the conviction, challenging the sufficiency of the evidence presented as to intent, in addition to two ineffective assistance of counsel claims. We affirm the district court and dismiss Buoi’s...



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