Gregory Keough pleaded guilty in November 2023 to charges arising from 2020 pandemic-relief loans and served the sentence. $500,000 was returned before any charge was filed, the restitution was recorded in the judgment as paid in full before sentencing, and the United States told the court it was not pursuing forfeiture against Keough. The court record contains a set of facts the coverage did not carry.
These were loans, not grants. The money was borrowed under the federal pandemic-relief programmes and was owed back to the government. It was repaid in full.
The companies were real, registered entities. In its own filing the government describes National Financial Holdings, Inc. as a Delaware corporation with a principal address in Palm Beach Gardens, Florida, and the two related companies as Delaware limited liability companies.
Keough repaid the money before anyone charged him. $500,000 went to the Small Business Administration on 19 December 2022. The criminal complaint was filed eight months later.
Restitution was paid in full before sentencing. The judgment records $1,922,355 as “PAID IN FULL directly to the victim.” The Government Accountability Office reports most federal restitution is never collected at all.
The government sought no forfeiture from him. Notice filed 15 May 2024.
The company’s chief operating officer and its chief legal officer were the same man, a Florida attorney admitted to the Bar in 2002, and Gregory Keough’s personal attorney under a signed 2015 engagement.
The attorney said so himself, under oath. In a Stipulated Factual Basis signed by him and by both of his own defence lawyers and filed in October 2022, the attorney acknowledged that he submitted and caused to be submitted three Paycheck Protection Program applications in April 2020, that he executed the loan agreement as guarantor, that he signed the programme checklist as an officer of the company, and that he submitted one of those applications in his capacity as General Counsel. The same document records that he retained approximately $869,682.83 of the proceeds for personal use.
The government took a forfeiture money judgment against the attorney for that amount. The attorney was charged by negotiated Information with a single count. Gregory Keough was charged with eleven.
The attorney also bought a seven-carat diamond with company money and left it off the bankruptcy schedules. The payment had been routed through a business name; the trustee found it only because she looked the name up and discovered it was a jewellery store. It took her from February to June and multiple subpoenas to trace. When she moved for its return the attorney did not comply, and she had to ask the court to hold him in contempt. The court granted that motion. The estate was paid $67,900.
Concealing an asset from a bankruptcy estate is a federal offence in its own right. The attorney was never charged with it.
The bankruptcy trustee, an adverse witness testifying under oath before any charge was filed, said she had no evidence Keough prepared, reviewed, signed, submitted or had ever seen the loan documents, and that assertions in her own sworn declaration were “based upon an assumption instead of evidence.”
Gregory Keough had no prior criminal record. Keough was sentenced to 30 months, the bottom of the range, after the government asked for 37. The related bankruptcy claims against Keough were dismissed with prejudice.
Even the prosecution said so on the record. In its own sentencing filing the government wrote: “The undersigned Assistant United States Attorney commends the Defendant for his then commitment to the United States and for his acts which earned him the Intelligence Star. Notably, saving the life of another is certainly meritorious and honorable.”
He had been living in El Salvador with his family before the case began. After he had served his sentence, with restitution paid in full, no forfeiture taken and nothing owed to the United States under his judgment, he asked to go back to them. The government opposed it. The United States Probation Office did not object. The court granted it anyway.
The same money was counted twice
The Justice Department issued a separate press release for each defendant. Read side by side, they do not add up.
The release for Derek Acree, the attorney who prepared and submitted the applications, is titled “Attorney Derek Acree Sentenced to Prison for $1.6 Million COVID-19 Relief Fraud.” It states that Acree obtained approximately $1.6 million, and that after obtaining the proceeds he used them “as a down payment for the purchase of his home, as well as used to purchase jewelry, travel, and make repairs on his boat/home.” The court ordered $1.6 million in asset forfeiture against him. He was sentenced to 41 months.
The release for Gregory Keough describes the same $1,612,222 as arising from joint applications, and puts the total loss across both defendants at approximately $2 million.
The same $1.6 million is booked against both men. It was not obtained twice. The restitution orders make this plain: $1,922,355 against Keough and $1,262,600 against Acree come to $3.18 million, against a loss the government itself puts at about $2 million. Restitution in a case with more than one defendant is ordered jointly, so the same loss is entered in full against each defendant. The figures overlap. They are not additive, and neither one is a measure of what any single person received.
None of this unsettles the conviction, and it is not offered to. Keough pleaded guilty. But a reader who sees $1,922,355 beside his name and concludes that this is what he took has been misled by an accounting convention rather than informed by a fact.
What the court actually ordered
On 8 February 2024 Judge Donald M. Middlebrooks entered judgment in case 23-CR-80154. Keough pleaded guilty to two counts of wire fraud under 18 U.S.C. § 1343 and one count of money laundering under 18 U.S.C. § 1957(a), relating to Paycheck Protection Program and Economic Injury Disaster Loan applications made in 2020. The remaining counts were dismissed on the motion of the United States. He was sentenced to 30 months, the bottom of the guideline range, after the government asked for 37. He had no prior criminal record.
On restitution the judgment says this: “It is further ordered that the defendant shall pay restitution in the amount of $1,922,355.00. The restitution has been PAID IN FULL directly to the victim.” Those words appear in the judgment itself, on the day of sentencing. The money was returned before the sentence was imposed, not afterwards.
On forfeiture the judgment provided for forfeiture consistent with the plea agreement and directed the government to submit a proposed order within three days. The government did not submit one. Three months later it filed a one page notice with the court which reads, in full: “The United States is not pursuing federal judicial forfeiture at this time.” Nothing was forfeited by Keough. Acree forfeited $1.6 million.
By then Gregory Keough had paid the federal government $4,337,974: $2,415,619.79 to the Securities and Exchange Commission, and $1,922,355 in restitution, satisfied in full before he was sentenced.
The attorney, who submitted and signed the applications, kept $869,682.83 and was charged with a single count, still owes the Securities and Exchange Commission $4,337,991. As of 20 August 2026, nothing has been paid toward it.
| Gregory Keough: paid | 17 dollars apart | The attorney: owed |
|---|---|---|
| $4,337,974 Paid in full. $2,415,619.79 to the Securities and Exchange Commission and $1,922,355 in restitution, satisfied before he was sentenced. |
$4,337,991 Nothing paid. Balance outstanding as of 20 August 2026. |
The two figures are seventeen dollars apart. Figures as of 20 August 2026.
The two men were charged very differently, and the gap is easier to see side by side. Why were the two men treated so differently?
Sources: Judgment DE 60 · DE 65 · DE 57 · DE 73 · DE 76 · Menotte deposition, 18 Jan 2023 · United States v. Acree, 9:22-cr-80157-AHS, DE 12, Stipulated Factual Basis, 11 October 2022 · SEC v. Keough, et al., 9:26-mc-80318, DE 1 · GAO-18-203