United States v. Adekoya

MEMORANDUM ORDER

JOSEPH N. LAPLANTE, District Judge.

This case raises a question as to the proof required to secure a conviction for bank fraud under 18 U.S.C. § 1344. The defendant, Olawaseun Adekoya, was among the targets of a sting operation conducted by the United States Secret Service. A Secret Service agent, impersonating as an associate of Adekoya’s, wrote an e-mail to Adekoya inviting him to participate in an “ATM cashout,” a scheme using fraudulently manufactured ATM cards to make unauthorized withdrawals from actual bank accounts. Adekoya took the bait, and recruited four other people…