The SNAP program uses federal tax dollars to help low-income households purchase food. SNAP recipients use Electronic Benefit Transfer (“EBT”) cards—similar to debit cards—to buy food at participating stores. Those stores, which get license numbers from the USDA, use special EBT terminals to swipe the EBT cards. When a SNAP recipient swipes their EBT card, the system verifies the transaction and electronically deducts the purchase amount from the recipient’s account. The corresponding federal funds are then transferred to the store’s bank account.

Starting in 2019, KEHOE orchestrated a network that supplied approximately 160 unauthorized EBT terminals to stores across the New York area to illegally process more than $30 million in EBT transactions. Working with his codefendants NAWAFLEH, OMAR ALRAWASHDEH, OBAID, and EMAD ALRAWASHDEH, KEHOE submitted approximately 200 fraudulent USDA applications, misappropriating USDA license numbers and, in some cases, doctoring application documents, to obtain EBT terminals for unauthorized stores—including smoke shops and other ineligible businesses.