An indictment was unsealed earlier today in federal court in Brooklyn charging Keily Nunez, Julien Levy, Ivan Santos and Ramnik Soni with conspiracy to commit honest services wire fraud and money laundering conspiracy. The charges arise from a scheme in which Nunez, a former employee of a U.S. airline headquartered in Long Island City, New York (Company 1), accepted more than $1 million in kickbacks in exchange for steering Company 1 aircraft part purchase orders to Summit Aviation Supply LLC (Summit LLC), a New Jersey-based company controlled by Levy and Santos; and to Alaris Aerospace Systems LLC (Alaris), a Florida-based company controlled by Soni. Summit LLC and Alaris secured more than $1.5 million and more than $8.5 million, respectively, in purchase orders from Company 1 during the conspiracy. Levy was arrested yesterday; Santos and Nunez were arrested today and all three were arraigned this afternoon before United States Magistrate Judge Roanne L. Mann. Levy was released on a $400,000 bond, Santos on a $150,000 bond, and Nunez on a $150,000 bond. Soni was arrested today and will be arraigned tomorrow.
Breon Peace, United States Attorney for the Eastern District of New York, and Ricky J. Patel, Special Agent-in-Charge, Homeland Security Investigations, New York (HSI), announced the arrests and charges.
“As alleged, the defendants were at the helm of a corrupt scheme to defraud an airline by diverting contracts to vendors in exchange for more than $1 million in kickbacks,” stated United States Attorney Peace. “This Office is committed both to protecting the integrity of the bidding process and ensuring that businesses compete on a level, honest playing field.” Mr. Peace thanked Internal Revenue Service Criminal Investigation for its assistance with the investigation.
As alleged in the indictment, between approximately July 2017 and June 2021, Levy, Nunez and Santos conspired to defraud Company 1 of the honest services of its employees, including Nunez and another Company 1 employee (“Co-Conspirator 1”). In their roles with Company 1, Nunez and Co-Conspirator 1 were responsible for contacting after-market aircraft parts sellers on behalf of Company 1 and filling Company 1’s part requisitions using a solicitation process that typically involved three price quotes and a comparison to historical prices Company 1 had paid for a given part. In their roles, Nunez and Co-Conspirator 1 could request that Company 1 add new aircraft part sellers as business partners to Company 1’s internal ordering system. Upon making such a request, Nunez and Co-Conspirator 1 were required by Company 1’s policies to disclose whether they had a business or financial relationship with the new business partner.
In order to carry out the scheme, Nunez allegedly used his position within Company 1 to establish Summit LLC as a Company 1 business partner and falsely represented to Company 1 that Summit LLC was another entity, Summit Corp., that Company 1 had previously partnered with. In reality, Santos established Summit LLC and opened bank accounts in its name, and Levy created an email account in the name of an individual who had been associated with the defunct Summit Corp., that was used as an alias to communicate with Company 1 on behalf of Summit LLC. Nunez approved approximately 37 purchase orders between Summit LLC and Company 1 valued at over $1.5 million. In exchange, Nunez received multiple kickback payments representing a percentage of the purchase orders directed to Summit LLC. In addition, following the termination of Nunez’s employment with Company 1, Nunez contacted Co-Conspirator 1 about steering Company 1’s purchase orders to Summit LLC and Alaris in exchange for a portion of the invoiced amounts. Co-Conspirator 1 agreed and subsequently directed Company 1 purchase orders, at inflated prices, to Summit LLC and Alaris in exchange for a percentage of some of the invoices Co-Conspirator 1 approved.
Nunez carried out a similar scheme with Soni and Alaris. Between approximately March 2017 and July 2019, Nunez allegedly approved approximately 109 invoices between Alaris and Company 1 valued at over $8.5 million. In exchange, Nunez received wires totaling hundreds of thousands of dollars sent from Alaris to bank accounts held in the name of FI USA Consulting LLC (FI USA), an entity controlled by Nunez. For example, between approximately October 2017 and January 2021, the FI USA accounts received approximately 17 wires from Alaris totaling approximately $536,940.
In order to disguise the source and nature of the funds Summit LLC received from the scheme, Santos and Levy made multiple transfers of the proceeds from the Company 1 payments between bank accounts in their names.
The charges in the indictment are allegations, and the defendants are presumed innocent unless and until proven guilty. If convicted, the defendants face up to 20 years in prison.
The government’s case is being handled by the Office’s Business and Securities Fraud Section. Department of Justice Trial Attorney Patrick J. Campbell and Assistant United States Attorney Garen S. Marshall are in charge of the prosecution.
Englewood, New Jersey
Jamaica, New York
New City, New York
E.D.N.Y. Docket No. 22-CR-281 (BMC)