Yesse Yehudah Indictment - Fulfilling Our Responsibilities Unto Mankind, Also Known As FORUM

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION
UNITED STATES OF AMERICA )

) Case No.
v. )
)
) Violations: Title 18, United States
YESSE YEHUDAH ) Code, Sections 1343 and 1344
COUNT ONE
The SPECIAL JANUARY 2019 GRAND JURY charges:
1. At times material to this indictment:
Relevant Individuals and Entities
a. Fulfilling Our Responsibilities Unto Mankind (“FORUM”) was a
not-for-profit organization based in Chicago, Illinois.
b. MTW Consultants was an Illinois corporation.
c. The Urban Institute was an Illinois corporation.
d. Defendant YESSE YEHUDAH was the President and Chief
Executive Officer of FORUM, MTW Consultants, and the Urban Institute.
e. FORUM and/or YEHUDAH owned commercial properties located
at 14818, 14828 and 14830 Chicago Road in Dolton, Illinois (the “Dolton Properties”).
FORUM also owned a vacant parcel of land at 14808 Chicago Road, Dolton, Illinois
(the “Vacant Lot”).

f. The Illinois Department of Commerce and Economic Opportunity
(“DCEO”) was an executive agency of Illinois’ state government. The DCEO awarded
grants to public and private organizations to promote economic development.
g. Individual A was an associate of YEHUDAH’s.
h. Individual B was Individual A’s sibling.
DCEO Grant Procedures
i. To obtain a DCEO grant, an organization could submit an
application directly to the DCEO for general grant funds, or lobby the Illinois
legislature to obtain a specific DCEO grant appropriation. In either scenario, before
an organization could receive grant funds, the applicant/grantee was required to
submit a proposed grant project plan to the DCEO that included a detailed proposed
budget for grant funds. If the DCEO approved the plan, the DCEO entered into a
“Grant Agreement” with the applicant/grantee. The Grant Agreement required the
grantee to perform a specific project designed to promote economic development;
adhere to a DCEO-approved budget prescribing how the grantee was to use grant
funds to execute the project, and to submit to regular monitoring by the DCEO to
ensure that the grantee was spending public grant funds in accordance with the
approved budget.
j. Under the terms of its Grant Agreements, the DCEO required
grantees to submit quarterly “Grantee Status Reports” regarding the progress of the
grant-funded project and the expenditure of grant funds. As part of the Grantee
Status Reports, the grantee was required to submit supporting documentation to the
2
DCEO, including bills, invoices, checks, and/or bank statements, as evidence to show
that the grantee was spending grant funds in accordance with the DCEO-approved
grant budget. The DCEO required authorized representatives of the grantees to sign
all Grantee Status Reports, and certify that all information contained within the
report was true and correct.
k. DCEO Grant Agreements included a notification provision that
stated, in pertinent part:
The Grantee shall notify the Departmental grant manager

in writing no later than 10 days after it becomes aware of
any events/circumstances that will result in substantial
delays or may substantially impair the Grantee’s ability to
complete the activities/performance described in [the
budget section].
l. DCEO Grant Agreements included a fiscal recording requirement
provision that stated, in pertinent part:
The Grantee’s financial management system shall be

structured to provide for accurate, current, and complete
disclosure of the financial results of the Project funded
under this grant program. The Grantee is accountable for
all Grant Funds received under this Grant, including those
expended for sub grantees . . . The Grantee shall keep
records sufficient to permit the tracing of Grant Funds to a
level of expenditure adequate to insure that Grant Funds
have not been inappropriately expended, and must have
internal controls consistent with generally accepted
accounting practices adopted by the American Institute of
Certified Public Accountants.
m. DCEO Grant Agreements contained a records retention policy
that stated, in pertinent part:
The Grantee is accountable for all Grant Funds received

under this Agreement and shall maintain, for a minimum
3
of four (4) years following the Department’s final written
approval of all required close-outs . . . adequate books,
records, and supporting documents, including digital and
electronic data, to verify the amount, recipients and uses of
all disbursements of Grant Funds.
n. DCEO Grant Agreements included a conflicts of interest
provision that stated, in pertinent part:
A conflict of interest exists if a Grantee’s officers, directors,

agents, employees and family members use their position
for a purpose that is, or gives the appearance, of being
motivated by a desire for a private gain, financial or
nonfinancial, for themselves or others, particularly those
with whom they have family business or other ties. The
Grantee must establish safeguards to prohibit such a
conflict of interest from occurring . . . The Grantee must
immediately notify the Department in writing of any actual
or potential conflicts of interest, as well as any actions that
create or which appear to create a conflict of interest.
Grants 1, 2, and 3
o. On or about June 14, 2013, YEHUDAH, on behalf of FORUM,
applied to the DCEO for a capital development grant to renovate the Dolton
Properties. On or about April 30, 2014, the DCEO sent FORUM a proposed Grant
Agreement for Grant Award Number 13-203322, a $225,000 DCEO award grant to
fund FORUM’s proposed renovations of the Dolton Properties (“Grant 1”). On or about
May 1, 2014, YEHUDAH, on behalf of FORUM, signed the Grant 1 Agreement. On
or about May 21, 2014, the DCEO gave final approval to Grant 1. Between
approximately May 22, 2014, and October 1, 2014, the DCEO distributed $225,000 in
Grant 1 funds to FORUM in multiple disbursements.
4
p. On or about June 23, 2014, YEHUDAH, on behalf of FORUM,
applied to the DCEO for an economic development grant to implement a building
weatherization specialist training programing. On or about December 16, 2014, the
DCEO sent FORUM a proposed Grant Agreement for Grant Award Number 15-
142005, a $250,000 DCEO grant award to fund FORUM’s proposed weatherization
specialist training program (“Grant 2”). On or about December 17, 2014, YEHUDAH,
on behalf of FORUM, signed the Grant 2 Agreement. On or about December 29, 2014,
the DCEO gave final approval to Grant 2. Between approximately January and June,
2015, the DCEO disbursed approximately $156,805.93 of Grant 2 funds in multiple
disbursements to FORUM. In awarding and disbursing Grant 2, it was material to
DCEO that YEHUDAH and FORUM abide by the Grant 2 Agreement conflict of
interest provision.
q. On or about August 29, 2014, YEHUDAH, on behalf of FORUM,
applied to the DCEO for a capital development grant to build a professional training
center on the Vacant Lot at which to train participants in FORUM’s weatherization
specialist training program. On or about January 7, 2015, the DCEO sent FORUM
a proposed Grant Agreement for Grant Award Number 15-203187, a $100,000 DCEO
grant award to fund FORUM’s construction of a professional training facility at the
Vacant Lot (“Grant 3”). On or about January 7, 2015, YEHUDAH, on behalf of
FORUM, signed the Grant 3 Agreement. On or about January 12, 2015, the DCEO
gave final approval to Grant 3. Between approximately January 2015 and November
5
2016, the DCEO distributed $100,000 of the Grant 3 funds in multiple disbursements
to FORUM.
2. Beginning no later than in or around January 2015, and continuing until
in or around September 2018, at Chicago, in the Northern District of Illinois, and
elsewhere,
YESSE YEHUDAH,
defendant herein, along with others known and unknown to the Grand Jury,
knowingly devised, intended to devise, and participated in a scheme to defraud the
DCEO, and to obtain money and property from the DCEO, by means of materially
false and fraudulent pretenses, representations, and promises, which scheme is
further described below.
3. It was part of the scheme that YEHUDAH fraudulently converted
substantial quantities of Grant 1, Grant 2, and Grant 3 funds by making materially
false statements to the DCEO. Specifically, YEHUDAH submitted false Grantee
Status Reports to the DCEO that falsely represented that FORUM was spending
Grant 1, Grant 2, and Grant 3 funds in accordance with the DCEO-approved budgets,
when in fact YEHUDAH had fraudulently converted substantial quantities of the
grant funds. YEHUDAH made the false representations to the DCEO in order to
continue to receive further grant funds, to conceal and avoid detection of his
conversion of DCEO funds, and to prevent the DCEO from recouping grant funds
and/or terminating the grants.
6
4. It was further part of the scheme that YEHUDAH generated and caused
to be generated forged invoices that fraudulently inflated the amounts that
subcontractors had billed FORUM for construction and renovation work at the Dolton
Properties and the Vacant Lot that the DCEO had approved under the Grant 1 and
Grant 3 budgets, respectively.
5. It was further part of the scheme that YEHUDAH generated and caused
to be generated fraudulently inflated checks that purported to show that FORUM
had paid the subcontractors amounts that were substantially higher than what
FORUM actually paid the subcontractors for construction and renovation work at the
Dolton Properties and the Vacant Lot.
6. It was further part of the scheme that YEHUDAH submitted and caused
to be submitted to the DCEO the forged invoices and fraudulently inflated checks to
support the materially false information contained in the Grantee Status Reports for
Grant 1 and Grant 3.
7. It was further part of the scheme that, after FORUM issued the
fraudulently inflated checks to the subcontractors, YEHUDAH directed the
subcontractors to endorse the checks over to YEHUDAH personally.
8. It was further part of the scheme that YEHUDAH deposited the
fraudulently inflated checks made out to the subcontractors but later endorsed over
to YEHUDAH into personal bank accounts over which YEHUDAH had signatory
authority.
7
9. It was further part of the scheme that, after depositing the fraudulently
inflated checks into his personal bank accounts, YEHUDAH paid the subcontractors
in cash in amounts that were substantially lower than the amounts on the
fraudulently inflated FORUM checks that YEHUDAH had made out to the
subcontractors and kept the remaining money for himself.
10. It was further part of the scheme that, in some cases, YEHUDAH,
without the knowledge or permission of the subcontractors, forged the subcontractors’
signatures on the backs of FORUM checks to endorse the checks over to himself, and
then kept the full check amount.
11. It was further part of the scheme that YEHUDAH fraudulently
converted to his own personal use Grant 1, Grant 2, and Grant 3 funds that he falsely
represented, and caused to be falsely represented to the DCEO, had been used to pay
subcontractors in accordance with the DCEO-approved grant budgets.
12. It was further part of the scheme that YEHUDAH concealed and caused
to be concealed from the DCEO that the FORUM checks made out to subcontractors
and presented to the DCEO in Grantee Reports had been endorsed over to
YEHUDAH and deposited into his personal bank accounts.
13. It was further part of the scheme that YEHUDAH used substantial
amounts of Grant 2 funds to pay individuals and entities with whom YEHUDAH and
FORUM had conflicts of interest (as defined in the Grant 2 Agreement), without
notifying the DCEO of the conflicts of interest as required under the Grant 2
Agreement. Specifically, between March and December 2015, YEHUDAH caused
8
FORUM to pay approximately $65,000 in Grant 2 funds to MTW Consultants and the
Urban Institute, without disclosing to the DCEO that YEHUDAH owned and
controlled these entities.
14. It was further part of the scheme that, on or about March 24, 2015,
YEHUDAH had FORUM issue a $20,000 check to Individual A. After FORUM issued
the $20,000 check to Individual A, YEHUDAH directed Individual A to endorse the
check over to YEHUDAH personally, and YEHUDAH deposited the check into his
personal bank account. YEHUDAH then used the funds to obtain a $20,000 cashier’s
check that he used to purchase a condominium in Individual A’s name for Individual
B. YEHUDAH later falsely represented to the DCEO that FORUM paid the $20,000
to Individual A for weatherization training services that the DCEO had approved
under the Grant 2 budget, when in fact Individual A had not performed the reported
services. Later, YEHUDAH collected at least $1,600 from Individual B to reimburse
YEHDUAH for the $20,000 in Grant 2 funds that he had given to Individual A to
purchase the condominium for Individual B.
15. It was further part of the scheme that, on or about May 12, 2015, after
the DCEO initiated a review of FORUM’s compliance with the terms of the Grant 2
agreement, YEHUDAH signed and submitted to the DCEO a “Certification of No
Conflict of Interest” form in which he falsely certified that FORUM was not using any
Grant 2 funds to pay individuals or entities with whom FORUM, its officers, or
employees had an actual or apparent conflict of interest.
9
16. It was further part of the scheme that, on or about June 30, 2015,
YEHUDAH submitted to the DCEO a Grant Report for Grant 3 that falsely
represented that FORUM had expended almost all of the $100,000 in grant funds on
construction work at the Vacant Lot when, in fact, no actual construction work had
begun.
17. It was further part of the scheme that YEHUDAH failed to notify the
DCEO that construction work had not begun at the Vacant Lot, as he was required
to do pursuant to the Grant 3 Agreement.
18. It was further part of the scheme that, after the DCEO initiated a review
of FORUM’s compliance with the terms of the Grant 3 Agreement, YEHUDAH forged
and fabricated, and caused to be forged and fabricated, invoices and letters that
falsely represented that FORUM had made “retainer fee” payments to certain
subcontractors in connection with the Vacant Lot project, when in fact no such
payments had been made.
19. It was further part of the scheme that YEHUDAH sent the forged and
fabricated invoices and letters to a DCEO employee conducting DCEO’s review of
FORUM’s compliance with the terms of the Grant 3 Agreement.
20. It was further part of the scheme that YEHUDAH and FORUM failed
to generate and maintain accurate accounting records of FORUM’s expenditure of
DCEO grant funds, as required under the Grant 1, Grant 2, and Grant 3 Agreements.
10
21. It was further part of the scheme that YEHUDAH and others
misrepresented, concealed, and hid, and caused to be misrepresented, concealed, and
hid, the existence, purpose, and acts done in furtherance of the scheme.
22. On or about May 12, 2015, at approximately 7:35 p.m., at Chicago, in
the Northern District of Illinois, Eastern Division, and elsewhere,
YESSE YEHUDAH,
defendant herein, for purposes of executing the above-described scheme, knowingly
caused to be transmitted by means of wire communication in interstate commerce,
certain writings, signs, and signals, namely, an electronic mail communication from
an email server located in the State of Washington to an email server located in the
State of Illinois in which YEHUDAH falsely certified that FORUM was not using
Grant 2 funds to pay individuals or entities with whom/which FORUM had a conflict
of interest;
In violation of Title 18, United States Code, Section 1343.
11
COUNT TWO
The SPECIAL JANUARY 2019 GRAND JURY further charges:
1. The allegations contained in paragraphs 1 through 21 of Count One are
re-alleged and incorporated here.
2. On or about June 18, 2015, at approximately 2:32 p.m., at Chicago, in
YESSE YEHUDAH,
State of Illinois, which email contained a Grantee Status Report in which YEHUDAH
falsely represented that FORUM had spent $20,000 in Grant 2 Funds on an approved
cost, when in fact YEHUDAH had diverted the funds for an unauthorized use, and
failed to disclose FORUM’s conflicts of interest with entities it was paying with Grant
2 funds;
12
COUNT THREE
2. On or about June 30, 2015, at approximately 5:30 p.m., at Chicago, in
YESSE YEHUDAH,
an email server located in the State of Washington, to an email server located in the
falsely represented the amounts of Grant 3 Funds that FORUM paid to certain
subcontractors;
13
COUNT FOUR
2. On or about July 14, 2015, at approximately 4:31 p.m., at Chicago, in
YESSE YEHUDAH,
2 funds;
14
COUNT FIVE
2. On or about April 26, 2016, at approximately 8:23 a.m., at Chicago, in
YESSE YEHUDAH,
2 funds;
15
COUNT SIX
2. On or about September 21, 2016, at approximately 11:49 a.m., at
Chicago, in the Northern District of Illinois, Eastern Division, and elsewhere,
YESSE YEHUDAH,
an email server in the State of Washington to an email server in the State of Illinois,
which email contained a Grantee Status Report in which YEHUDAH falsely
represented the amounts of Grant 3 Funds that FORUM paid to certain
subcontractors;
16
COUNT SEVEN
2. On or about February 8, 2017, at approximately 2:37 p.m., at Chicago,
in the Northern District of Illinois, Eastern Division, and elsewhere,
YESSE YEHUDAH,
an email server in the State of Washington to an email server in the State of Illinois,
in which YEHUDAH falsely represented that FORUM had used Grant 3 funds to
make upfront “retainer” payments to certain subcontractors;
17
COUNT EIGHT
1. The allegations contained in paragraphs 1(a) and 1(c) of Count One are
2. At times material to this indictment:
a. The Associated Banc-Corp (“Associated Bank”) was a financial
institution whose deposits were insured by the Federal Deposit Insurance
Corporation.
b. The Associated Bank accepted checks issued by a depositor to an
original payee, who later endorsed the check over to a third party. In accepting a
depositor’s check that had been endorsed over to a third party, it was material to the
Associated Bank that the original payee or an authorized representative knowingly
signed the check over to the third party.
c. FORUM received grants from various entities, including the
DCEO, the United States Department of Housing and Urban Development (“HUD”),
and the Community and Economic Development Association of Cook County
(“CEDA”) to renovate and restore residential and commercial properties in the
Chicago area.
d. FORUM hired various subcontractors, including Individual C and
Company 1, Individual D and Company 2, Individual E and Company 3, and
Individual F and Company 4, to perform renovation work on properties that it
received grant funds to renovate and restore.
18
3. Beginning no later than in or around February 2012, and continuing
until in or around September 2015, at Chicago, in the Northern District of Illinois,
and elsewhere,
YESSE YEHUDAH,
defendant herein, participated in a scheme to obtain money owned by and under the
custody and control of the Associated Bank, by means of materially false and
fraudulent pretenses, representations, and promises, as further described below.
4. It was part of the scheme that YEHUDAH issued, and caused to be
issued, checks that drew on FORUM’s and the Urban Institute’s bank accounts at the
Associated Bank, made payable to various individuals and companies (the “original
payees”) that YEHUDAH at times hired to perform construction and renovation work
for FORUM.
5. It was further part of the scheme that YEHUDAH, without the
knowledge or approval of the original payee, forged the original payee’s signature (or
the signature of an authorized signatory of the original payee), for purposes of falsely
endorsing the FORUM and the Urban Institute checks over to YEHUDAH.
6. It was further part of the scheme that YEHUDAH deposited or cashed,
and caused to be deposited or cashed, the FORUM and the Urban Institute checks
that he had falsely endorsed over to himself at financial institutions, including
Associated Bank.
19
7. On or about June 6, 2012, at Chicago, in the Northern District of Illinois,
Eastern Division, and elsewhere,
YESSE YEHUDAH,
defendant herein, knowingly executed the scheme and attempted to do so by
obtaining $1,500 from FORUM’s bank account at Associated Bank, by presenting and
cashing, and causing to be presented and cashed, a check made payable to Individual
C and Company 1, that YEHUDAH falsely endorsed over to himself;
In violation of Title 18, United States Code, Sections 1344(2).
20
COUNT NINE
1. The allegations contained in paragraphs 1(a) and 1(c) of Count One and
the allegations contained in paragraphs 2 through 6 of Count Eight are re-alleged
and incorporated here.
2. On or about January 25, 2013, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,
YESSE YEHUDAH,
obtaining $800 from the Urban Institute’s bank account at Associated Bank, by
presenting and cashing, and causing to be presented and cashed, a check made
payable to Individual D and Company 2, that YEHUDAH falsely endorsed over to
himself;
21
COUNT TEN
2. On or about August 20, 2013, at Chicago, in the Northern District of
YESSE YEHUDAH,
22
COUNT ELEVEN
2. On or about March 6, 2015, at Chicago, in the Northern District of
YESSE YEHUDAH,
F and Company 4, that YEHUDAH falsely endorsed over to himself;
23
COUNT TWELVE
2. On or about March 11, 2015, at Chicago, in the Northern District of
YESSE YEHUDAH,
E and Company 3, that YEHUDAH falsely endorsed over to himself;
24
COUNT THIRTEEN
2. On or about May 15, 2015, at Chicago, in the Northern District of
YESSE YEHUDAH,
25
COUNT FOURTEEN
2. On or about September 30, 2015, at Chicago, in the Northern District of
YESSE YEHUDAH,
D and Company 2, that YEHUDAH falsely endorsed over to himself;
26
COUNT FIFTEEN
2. On or about September 30, 2015, at Chicago, in the Northern District of
YESSE YEHUDAH,
F and Company 4, that YEHUDAH falsely endorsed over to himself;
27
FORFEITURE ALLEGATION
The SPECIAL JANUARY 2019 GRAND JURY alleges:
1. Upon conviction of an offense in violation of Title 18, United States Code,
Sections 1343 or 1344, as set forth in this indictment, defendant shall forfeit to the
United States of America any property constituting and derived from proceeds
obtained directly and indirectly as a result of the offense, as provided in Title 18,
United States Code, Section 982.
2. The property to be forfeited includes, but is not limited to a personal
money judgment in the amount of $200,000.
3. If any of the property described above, as a result of any act or omission
by a defendant: cannot be located upon the exercise of due diligence; has been
transferred or sold to, or deposited with, a third party; has been placed beyond the
jurisdiction of the Court; has been substantially diminished in value; or has been
commingled with other property which cannot be divided without difficulty, the
United States of America shall be entitled to forfeiture of substitute property, as
provided by Title 21, United States Code Section 853(p).
A TRUE BILL:
______________________________
FOREPERSON
______________________________
UNITED STATES ATTORNEY
28

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

UNITED STATES OF AMERICA )

The SPECIAL JANUARY 2019 GRAND JURY charges:

1. At times material to this indictment:

Relevant Individuals and Entities

a. Fulfilling Our Responsibilities Unto Mankind (“FORUM”) was a

not-for-profit organization based in Chicago, Illinois.

b. MTW Consultants was an Illinois corporation.

c. The Urban Institute was an Illinois corporation.

d. Defendant YESSE YEHUDAH was the President and Chief

Executive Officer of FORUM, MTW Consultants, and the Urban Institute.

e. FORUM and/or YEHUDAH owned commercial properties located

(the “Vacant Lot”).

grants to public and private organizations to promote economic development.

g. Individual A was an associate of YEHUDAH’s.

h. Individual B was Individual A’s sibling.

DCEO Grant Procedures

i. To obtain a DCEO grant, an organization could submit an

legislature to obtain a specific DCEO grant appropriation. In either scenario, before

an organization could receive grant funds, the applicant/grantee was required to

grantee to perform a specific project designed to promote economic development;

j. Under the terms of its Grant Agreements, the DCEO required

report was true and correct.

k. DCEO Grant Agreements included a notification provision that

stated, in pertinent part:

The Grantee shall notify the Departmental grant manager

l. DCEO Grant Agreements included a fiscal recording requirement

provision that stated, in pertinent part:

The Grantee’s financial management system shall be

m. DCEO Grant Agreements contained a records retention policy

that stated, in pertinent part:

The Grantee is accountable for all Grant Funds received

n. DCEO Grant Agreements included a conflicts of interest

provision that stated, in pertinent part:

A conflict of interest exists if a Grantee’s officers, directors,

o. On or about June 14, 2013, YEHUDAH, on behalf of FORUM,

May 1, 2014, YEHUDAH, on behalf of FORUM, signed the Grant 1 Agreement. On

Grant 1 funds to FORUM in multiple disbursements.

applied to the DCEO for an economic development grant to implement a building

weatherization specialist training programing. On or about December 16, 2014, the

142005, a $250,000 DCEO grant award to fund FORUM’s proposed weatherization

2015, the DCEO disbursed approximately $156,805.93 of Grant 2 funds in multiple

disbursements to FORUM. In awarding and disbursing Grant 2, it was material to

q. On or about August 29, 2014, YEHUDAH, on behalf of FORUM,

center on the Vacant Lot at which to train participants in FORUM’s weatherization

grant award to fund FORUM’s construction of a professional training facility at the

Vacant Lot (“Grant 3”). On or about January 7, 2015, YEHUDAH, on behalf of

2. Beginning no later than in or around January 2015, and continuing until

in or around September 2018, at Chicago, in the Northern District of Illinois, and

knowingly devised, intended to devise, and participated in a scheme to defraud the

false and fraudulent pretenses, representations, and promises, which scheme is

further described below.

3. It was part of the scheme that YEHUDAH fraudulently converted

substantial quantities of Grant 1, Grant 2, and Grant 3 funds by making materially

false statements to the DCEO. Specifically, YEHUDAH submitted false Grantee

when in fact YEHUDAH had fraudulently converted substantial quantities of the

and/or terminating the grants.

to be generated forged invoices that fraudulently inflated the amounts that