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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ERISA Life Policy Requires Active Employment to Order Increase in Benefits
Post 5259
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In Katherine Crow Albert Guidry, Individually And On Behalf Of The Estate Of Jason Paul Guidry v. Metropolitan Life Insurance Company, et al, Civil Action No. 25-18-SDD-RLB, United States District Court, M.D. Louisiana (January 7, 2026) Guidry brought suit to recover life insurance proceeds she alleges were wrongfully withheld following her husband’s death on January 9, 2024.
FACTUAL BACKGROUND
Jason Guidry was employed by Waste Management, which provided life insurance coverage through Metropolitan Life Insurance Company (“MetLife”). Plaintiff contends that after Jason’s death, the defendants (MetLife, Waste Management, and Life Insurance Company of North America (“LINA”)) engaged in conduct intended to confuse and ultimately deny her entitlement to...
Failure to Respond to Motion to Dismiss is Agreement to the Motion
Post 5259
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In Mercury Casualty Company v. Haiyan Xu, et al., No. 2:23-CV-2082 JCM (EJY), United States District Court, D. Nevada (January 6, 2026) Plaintiff Mercury Casualty Company (“plaintiff”) moved to dismiss. Defendant Haiyan Xu and Victoria Harbor Investments, LLC (collectively, “defendants”) did not respond.
This case revolves around an insurance coverage dispute when the parties could not be privately resolved, litigation was initiated in the Eighth Judicial District Court of Nevada. Plaintiff subsequently filed for a declaratory judgment in this court.
On or about April 15, 2025, the state court action was dismissed with prejudice pursuant to a stipulation following mediation. Plaintiff states that the state court dismissal renders its ...
Overwhelming Evidence of Insurance Fraud Sustains Conviction - One Fraud Fails in Minnesota
Post 5258
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In State of Minnesota v. Mark John Jenni, No. A25-0111, Court of Appeals of Minnesota (January 5, 2026) dealt with an insurance coverage issue because Mr. Jenni, in July 2023, obtained an insurance policy with Liberty Mutual Insurance for a home in Park Rapids, Hubbard County, Minnesota based on false representations, only to find himself charged with insurance fraud.
FACTS
On his application, Jenni stated that the property was his primary residence, that he had purchased it in 2023, that it was not under construction or renovation, and that there had been no recent insurance claims or cancellations on the property. About a month after securing coverage, Jenni filed a claim for a reported burglary involving over $80,000 in stolen tools and property damage. He did not report the ...
Court Must Follow Judicial Precedent
Post 5252
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Insurance Policy Interpretation Requires Application of the Judicial Construction Doctrine
In Montrose Chemical Corporation Of California v. The Superior Court Of Los Angeles County, Canadian Universal Insurance Company, Inc., et al., B335073, Court of Appeal, 337 Cal.Rptr.3d 222 (9/30/2025) the Court of Appeal refused to allow extrinsic evidence to interpret the word “sudden” in qualified pollution exclusions (QPEs) as including gradual but unexpected pollution. The court held that, under controlling California appellate precedent, the term “sudden” in these standard-form exclusions unambiguously includes a temporal element (abruptness) and cannot reasonably be construed to mean ...
Lack of Jurisdiction Defeats Suit for Defamation
Post 5250
Posted on December 29, 2025 by Barry Zalma
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He Who Represents Himself in a Lawsuit has a Fool for a Client
In Pankaj Merchia v. United Healthcare Services, Inc., Civil Action No. 24-2700 (RC), United States District Court, District of Columbia (December 22, 2025)
FACTUAL BACKGROUND
Parties & Claims:
The plaintiff, Pankaj Merchia, is a physician, scientist, engineer, and entrepreneur, proceeding pro se. Merchia sued United Healthcare Services, Inc., a Minnesota-based medical insurance company, for defamation and related claims. The core allegation is that United Healthcare falsely accused Merchia of healthcare fraud, which led to his indictment and arrest in Massachusetts, causing reputational and business harm in the District of Columbia and nationwide.
Underlying Events:
The alleged defamation occurred when United ...
Zalma’s Insurance Fraud Letter
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ZIFL Volume 29, Issue 24
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Zalma’s Insurance Fraud Letter (ZIFL) continues its 29th year of publication dedicated to those involved in reducing the effect of insurance fraud. ZIFL is published 24 times a year by ClaimSchool and is written by Barry Zalma. It is provided FREE to anyone who visits the site at http://zalma.com/zalmas-insurance-fraud-letter-2/
Zalma’s Insurance Fraud Letter
Merry Christmas & Happy Hannukah
Read the following Articles from the December 15, 2025 issue:
Read the full 19 page issue of ZIFL at ...
