Guilty of Money Laundering Scheme
Post 5238
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Prison Sentence for Fraud Must be Limited to the Fraud in Which the Defendant Participated
In United States v. Stephen O. Anagor, No. 2:24-CR-00019-DCLC-CRW (E.D. Tenn., Nov. 26, 2025) by Judge Clifton L. Corker the government sought to increase the defendant’s sentence because his co-conspirators added a fraudulent FBI scam that resulted in the victim’s suicide. Anagor sought a lower sentence because he was only involved in part of the fraud.
Charges & Plea
Defendant, a U.S. Army soldier pled guilty on June 11, 2025 to Conspiracy to Commit Mail and Wire Fraud, Aiding and Abetting Aggravated Stalking Resulting in Death and Aiding and Abetting Aggravated Identity Theft that was part of a larger 38-count superseding indictment against Anagor and co-defendants Chinagorom Onwumere and Salma Abdalkareem for an international Nigerian-based romance-scam + follow-on “law-enforcement extortion” scheme.
Role of Anagor
Anagor recruited co-defendant Onwumere into the money-laundering side of the scam and received victim checks in the mail, deposited them into his own U.S. bank accounts, kept a cut, and wired the rest overseas (primarily to Nigeria).
Anagor purchased and sent flowers/gifts to victims to maintain the illusion of romance, knew the funds were proceeds of romance-scam fraud but did not know the specific communications with victims and was not aware that Nigerian co-conspirators were running a secondary “impersonate the FBI/Attorney General” extortion scheme on top of the romance scam.
Key Victim (Victim 1) & Tragic Outcome
An elderly retired teacher from Jonesborough, TN believed he was in a romantic relationship with a celebrity. Nude photos from scammers in Nigeria then switched to impersonating federal law enforcement, threatened exposure/arrest, and extorted $97,500 (his entire life savings) via checks and cashier’s checks sent to Onwumere/Abdalkareem.
After paying, the retired teacher faced continued threats that escalated to the point that Victim 1 sent suicidal messages to the scammers (thinking they were the “celebrity”) and on October 23, 2023 Victim 1 committed suicide.
Anagor knew Victim 1 was being targeted (saw his name and the laundering accounts in WhatsApp messages) and personally received $33,430 that originated from Victim 1’s money laundered through Onwumere/Abdalkareem, but he did not know about the law-enforcement impersonation, the threats, or the suicidal messages.
KEY LEGAL TAKEAWAYS FROM THE OPINION
Relevant Conduct (U.S.S.G. §1B1.3)
Anagor was responsible for the core romance-scam money-laundering activity he agreed to and could reasonably foresee, yet the court concluded he is not responsible for the Nigerian co-conspirators’ separate law-enforcement extortion tactics or knowledge of Victim 1’s suicidal ideation because those were outside the scope of the jointly undertaken activity he signed up for.
2B1.1(B)(16)(A) “Conscious Or Reckless Risk Of Death” In Fraud Cases
The statute requires either (i) subjective awareness, or (ii) objective recklessness. In the Sixth Circuit, the risk must be “actual, not conjectural.”
Mere participation in a romance scam that tragically ends in suicide is not enough for the enhancement when the defendant was unaware of the specific threats or victim’s mental state.
BOTTOM LINE
As of November 26, 2025, the court rejected the government’s attempts to add +4 levels to the fraud guideline calculation. The original (lower) offense level stands going into the December 2, 2025 sentencing hearing, where the court will still consider possible upward variances under 18 U.S.C. § 3553(a) because of the victim’s death and the overall egregiousness of the scheme.
ZALMA OPINION
Fraud schemes based in Nigeria have been rampant since I obtained adulthood in the 1960’s with even my older brother almost became a victim. Anagor, while serving as a soldier in the US Army participated in a fairly successful money laundering scheme by convincing an elderly man into a romance scam where he was led to believe he had a romantic involvement with a celebrity. The scheme went bad when they Nigerians claimed to be FBI agents who threatened him with arrest until he paid his life savings to the fraudsters. Anagor was allowed to be sentenced for the money laundering but not the FBI scheme that resulted in the victim’s suicide. He will be sentenced but not enhanced.
(c) 2025 Barry Zalma & ClaimSchool, Inc.
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Convicted Criminal Seeks to Compel Receiver to Protect his Assets
Post number 5291
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The Work of a Court Appointed Receiver is Constitutionally Protected
In Simon Semaan et al. v. Robert P. Mosier et al., G064385, California Court of Appeals, Fourth District, Third Division (February 6, 2026) the Court of Appeals applied the California anti-SLAPP statute which protects defendants from meritless lawsuits arising from constitutionally protected activities, including those performed in official capacities. The court also considered the doctrine of quasi-judicial immunity, which shields court-appointed receivers from liability for discretionary acts performed within their official duties.
Facts
In September 2021, the State of California filed felony charges against Simon Semaan, alleging violations of Insurance Code section 11760(a) for making...
When There are Two Different Other Insurance Clauses They Eliminate Each Other and Both Insurers Owe Indemnity Equally
Post number 5289
In Great West Casualty Co. v. Nationwide Agribusiness Insurance Co., and Conserv FS, Inc., and Timothy A. Brennan, as Administrator of the Estate of Pat- rick J. Brennan, deceased, Nos. 24-1258, 24-1259, United States Court of Appeals, Seventh Circuit (February 11, 2026) the USCA was required to resolve a dispute that arose when a tractor-trailer operated by Robert D. Fisher (agent of Deerpass Farms Trucking, LLC-II) was involved in a side-impact collision with an SUV driven by Patrick J. Brennan, resulting in Brennan’s death.
Facts
Deerpass Trucking, an interstate motor carrier, leased the tractor from Deerpass Farms Services, LLC, and hauled cargo for Conserv FS, Inc. under a trailer interchange agreement. The tractor was insured by Great West Casualty Company with a $1 million policy limit, while the trailer was insured by Nationwide Agribusiness Insurance Company with a $2 million ...
Opiod Producer Seeks Indemnity from CGL Insurers
Post number 5288
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Insurers Exclude Damages Due to Insured’s Products
In Matthew Dundon, As The Trustee Of The Endo General Unsecured Creditors’ Trust v. ACE Property And Casualty Insurance Company, et al., Civil Action No. 24-4221, United States District Court, E.D. Pennsylvania (February 10, 2026) Matthew Dundon, trustee of the Endo General Unsecured Creditors’ Trust, sued multiple commercial general liability (CGL) insurers for coverage of opioid-related litigation involving Endo International PLC a pharmaceutical manufacturer.
KEY FACTS
Beginning as early as 2014, thousands of opioid suits were filed by governments, third parties, and individuals alleging harms tied to opioid manufacturing and marketing.
Bankruptcy & Settlements
Endo filed Chapter 11 in August 2022; before bankruptcy it ...
Passover for Americans
Posted on February 19, 2026 by Barry Zalma
“The Passover Seder For Americans”
For more than 3,000 years Jewish fathers have told the story of the Exodus of the enslaved Jews from Egypt. Telling the story has been required of all Jewish fathers. Americans, who have lived in North America for more than 300 years have become Americans and many have lost the ability to read, write and understand the Hebrew language in which the story of Passover was first told in the Torah. Passover is one of the many holidays Jewish People celebrate to help them remember the importance of G_d in their lives. We see the animals, the oceans, the rivers, the mountains, the rain, sun, the planets, the stars, and the people and wonder how did all these wonderful things come into being. Jews believe the force we call G_d created the entire universe and everything in it. Jews feel G_d is all seeing and knowing and although we can’t see Him, He is everywhere and in everyone.We understand...
Passover for Americans
Posted on February 19, 2026 by Barry Zalma
Read the full article at https://www.linkedin.com/pulse/passover-americans-barry-zalma-esq-cfe-5vgkc.
“The Passover Seder For Americans”
For more than 3,000 years Jewish fathers have told the story of the Exodus of the enslaved Jews from Egypt. Telling the story has been required of all Jewish fathers. Americans, who have lived in North America for more than 300 years have become Americans and many have lostthe ability to read, write and understand the Hebrew language in which the story of Passover was first told in the Torah.
Passover is one of the many holidays Jewish People celebrate to help them remember the importance of G_d in their lives. We see the animals, the oceans, the rivers, the mountains, the rain, sun, the planets, the stars, and the people and ...
You Get What You Pay For – Less Coverage Means Lower Premium
Post number 5275
Posted on January 30, 2026 by Barry Zalma
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When Experts for Both Sides Agree That Two Causes Concur to Cause a Wall to Collapse Exclusion Applies
In Lido Hospitality, Inc. v. AIX Specialty Insurance Company, No. 1-24-1465, 2026 IL App (1st) 241465-U, Court of Appeals of Illinois (January 27, 2026) resolved the effect of an anti-concurrent cause exclusion to a loss with more than one cause.
Facts and Background
Lido Hospitality, Inc. operates the Lido Motel in Franklin Park, Illinois. In November 2020, a windstorm caused one of the motel’s brick veneer walls to collapse. At the time, Lido was insured under a policy issued by AIX Specialty Insurance Company which provided coverage for windstorm damage. However, the policy contained an exclusion for any loss or damage directly or indirectly resulting from ...
