Gregory Keough owes nothing. These were loans, not grants, and every dollar was repaid; by the government’s own figures he repaid more than he received, and he did it before he was charged. His restitution of $1,922,355 is recorded in the court’s judgment as “PAID IN FULL directly to the victim” before he was sentenced on 8 February 2024 (Judgment, DE 60, on CourtListener). The Department of Justice’s own sentencing announcement states that “restitution was paid in full.” He had repaid $500,000 to the Small Business Administration eight months before any charge was filed. The United States filed notice that it was not pursuing forfeiture against him. On 6 October 2026 the Securities and Exchange Commission confirmed in writing that his financial obligations to the Commission are fully satisfied and his file is closed. He pleaded guilty in November 2023 to charges arising from 2020 pandemic-relief loans, served a 30-month sentence, the bottom of the range, and was allowed by the court to return to his family in El Salvador.
- Restitution: $1,922,355, recorded in the judgment as paid in full before sentencing (Judgment, DE 60).
- Repaid before charges: $500,000 to the SBA on 19 December 2022; the complaint came eight months later.
- Forfeiture: none. The United States filed notice on 15 May 2024 that it was not pursuing forfeiture against him (DE 65).
- SEC: paid in full. SEC written confirmation of 6 October 2026: obligations “fully satisfied,” file closed.
- Sentence: 30 months, the bottom of the guideline range; the government had asked for 37. No prior record.
- Pretrial: “has met all conditions of pretrial release,” in the court’s own words (Order, DE 47).
- After release: the court granted his motion to live with his family in El Salvador; U.S. Probation had no objection (Order, DE 76).
- The companies were real, registered entities, in the government’s own description. The complaint said one of them took in $11,910 over thirteen months; its 2018 tax return reported $476,475 and the government’s own bank records show $413,509.93 deposited in that period.
- Most federal restitution is never collected at all (GAO-18-203). This one was paid before the sentence was handed down.
These facts belong alongside the headlines, and every one of them is in the public court record: $500,000 repaid before any charge was filed, restitution paid in full before sentencing, no forfeiture, the SEC matter closed as fully paid, and a court-appointed trustee, an adverse witness, who testified she had no evidence Gregory Keough prepared or submitted the loan applications.
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.
For one of those companies the government told the court $11,910 had come in over thirteen months. Its 2018 tax return reported $476,475, and the government’s own bank records show $413,509.93 deposited over those same thirteen months, $310,509.93 of it from other companies.
Keough repaid the money before anyone charged him. $500,000 went to the Small Business Administration on 19 December 2022, paid by Keough as personal guarantor of the loan (SBA payment confirmation; counsel’s letter to the U.S. Attorney’s Office). 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 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.”
Greg 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, nothing owed under his judgment and, since October 2026, nothing owed to the SEC, 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 SEC matter: paid in full and closed
Gregory Keough consented to the SEC’s 2021 Order without contest. The joint obligations under the Order were paid in full within days. His individual obligations were paid from the sale of his Montana property in March 2023, with his counsel keeping the SEC informed in writing throughout. A residual balance that arose from the Order’s interest-first allocation was paid in full in October 2026, within three weeks of the SEC providing a payoff figure. On 6 October 2026 the SEC confirmed in writing that the payment “fully satisfies” his financial obligations to the Commission and that his file is closed and marked as fully paid. More than $10 million has been paid under the Order.
How were Gregory Keough and the attorney treated?
Gregory Keough was indicted on eleven counts, jailed for 28 days and held under GPS home detention for six and a half months. The attorney who admitted submitting the loan applications was charged with a single count and released on a $500,000 bond, free to travel. Both men were charged out of the same loan applications. The case was investigated by the FBI in West Palm Beach. The attorney’s father had been an FBI Special Agent in Palm Beach County for three decades, retiring in 2001. The public record of each is set out below.
| Gregory Keough | The attorney | |
|---|---|---|
| Family tie to the investigating FBI office | None. | His father was an FBI Special Agent in Palm Beach County for three decades, retiring in 2001, then headed the State Attorney’s Office money-laundering task force. He died in 2008. |
| Held before trial | Arrested. Held in jail for 28 days while the government sought to keep him detained. Released on $3 million in bonds to six and a half months of home detention with a GPS monitor, which he paid for, until he surrendered to serve his sentence. | Released on a $500,000 personal surety bond, co-signed by his wife. No home detention. No location monitoring. Permitted to travel anywhere in the continental United States. |
| Legal role | Co-founder. Not an attorney. | Chief Legal Officer of the DeFi Money Market business (SEC order, para. 10). General Counsel of the lending company, in which capacity he submitted a loan application (Stipulated Factual Basis). Keough’s personal attorney under a 2015 engagement letter. |
| Submitted and signed the loan applications | The bankruptcy trustee, an adverse witness, testified she had no evidence Keough prepared, reviewed, signed, submitted or had ever seen them (Menotte deposition, 18 January 2023). | Yes. Admitted under oath in his own signed factual basis, October 2022, including one application submitted in his capacity as General Counsel. His factual basis also states that he provided the falsified bank statements submitted with a PPP application. |
| How each was charged | Indicted on eleven counts, August 2023. | Charged by negotiated Information on a single count, 27 September 2022, eleven months earlier. |
| Forfeiture | None. The United States sought no forfeiture (Notice on Forfeiture, DE 65). | A forfeiture money judgment of $869,682.83 (Preliminary Order of Forfeiture, DE 19). |
| Paid to the Securities and Exchange Commission | $2,415,619.79 wired 31 March 2023, and the remaining balance paid in October 2026. On 6 October 2026 the SEC confirmed in writing that his financial obligations to the Commission are “fully satisfied” and his file is closed. More than $10 million has been paid under the 2021 Order. Owes nothing. | Nothing as of 20 August 2026. $4,337,991 remains outstanding. |
| Assets concealed from the bankruptcy estate | The related bankruptcy claims against Keough were dismissed with prejudice. | A seven-carat diamond bought with company money and left off the schedules. The court granted the trustee’s motion for contempt. The attorney was never charged with it. |
| Restitution | $1,922,355, recorded in the judgment as paid in full before sentencing (Judgment, DE 60). | $1,262,600, recorded as satisfied in October 2023. |
Sources: Obituary, The Palm Beach Post, August 2008 · Criminal Complaint, DE 3, para. 2 · Bond, United States v. Keough, DE 28 · Bond order in the co-defendant’s case, DE 8
A man with no criminal history, whose restitution was recorded as paid in full and who had wired $2,415,619.79 to the Securities and Exchange Commission before he was sentenced, asked to go home to his wife and five children. The government fought it.
What did the government say the company earned, and what do the records show?
The government told the court Gregory Keough’s company NFH Partners took in $11,910 in thirteen months. Its own bank records show $413,509.93 deposited in the same account over the same months: $310,509.93 from other companies and $103,000 in transfers from Keough’s own accounts. The company’s 2018 tax return reported $476,475.
In its criminal complaint the government told the court that NFH Partners had about $11,910 in gross receipts over the thirteen months from January 2019 to January 2020 (Criminal Complaint, DE 3, para. 18).
The company’s 2018 federal tax return, prepared by its accountant in January 2019, more than a year before the pandemic loan programmes existed, reported $476,475 in revenue. The loan application, submitted in March 2020, stated $496,785, within 5 percent of it. It was the only tax return the company had on file that day.
| Amount | Source | |
|---|---|---|
| What the government told the court | $11,910 | Criminal Complaint, DE 3, para. 18 |
| All deposits, same account, same 13 months | $413,509.93 | TD Bank statements, government production |
| Of which, from other companies | $310,509.93 | same |
| Of which, transfers from Keough’s own accounts | $103,000.00 | same |
| 2018 tax return (prepared January 2019) | $476,475 | Form 1120-S |
| Loan application, March 2020 | $496,785 | Application |
Why do the dollar figures in the press releases overlap?
The government issued a separate press release for each defendant, and they do not add up.
The release about the attorney is headed with the figure $1.6 million and says he obtained approximately that amount. The release about Keough describes the same $1,612,222 as coming from joint applications, and puts the total loss across both men at about $2 million.
The same money appears in both. Restitution in a case with more than one defendant is ordered jointly, so the same loss is entered in full against each. $1,922,355 against Keough and $1,262,600 against the attorney total $3.18 million, against a $2 million loss. The figures overlap. Neither is a measure of what one person received.
Keough pleaded guilty and that is not in dispute. But the number beside his name is an accounting convention, not what he received.
What sentence did Gregory Keough receive?
Gregory Keough was sentenced to 30 months, the bottom of the guideline range, with restitution already recorded as paid in full before sentencing and no forfeiture (Judgment, DE 60; Notice on Forfeiture, DE 65).
On 8 February 2024 Keough was sentenced to 30 months, the bottom of the guideline range, after the government asked for 37. He pleaded guilty to two counts of wire fraud and one count of money laundering arising from Paycheck Protection Program and Economic Injury Disaster Loan applications made in 2020. The remaining counts were dismissed. He had no prior criminal record.
The judgment records the restitution in these words: “The restitution has been PAID IN FULL directly to the victim.” That line is in the judgment itself, dated the day of sentencing. Nothing was forfeited from Keough. The attorney agreed to a forfeiture money judgment of $869,682.83.
The federal government has received $4,337,974.79 in these matters: $2,415,619.79 to the Securities and Exchange Commission in the settled 2021 administrative proceeding concerning Blockchain Credit Partners, which traded as DeFi Money Market (DMM), and $1,922,355 in restitution. The judgment records the restitution as paid in full before sentencing.
What does the court record show about Gregory Keough?
- Keough repaid $500,000 before he was charged, and the restitution was recorded in the judgment as paid in full before he was sentenced. The government took no forfeiture from him.
- The bankruptcy trustee, an adverse witness, testified she had no evidence he prepared, signed or submitted the loan applications.
- The attorney, who admitted submitting them, was charged with one count, released on a $500,000 bond and free to travel. Keough was indicted on eleven counts, held in jail for 28 days, and kept under GPS home detention for six and a half months.
- The case was investigated by the FBI in the county where the attorney’s father had served as a Special Agent for three decades.
- The government told the court one company took in $11,910. Its tax return said $476,475.
Questions and answers
Was Gregory Keough’s restitution paid?
Yes, in full, before sentencing. The judgment in United States v. Keough records restitution of
Was Gregory Keough’s restitution paid?
,922,355 as “PAID IN FULL directly to the victim,” dated 8 February 2024, the day of sentencing (Judgment, DE 60, on CourtListener). The Department of Justice’s sentencing announcement states that “restitution was paid in full.”
Does Gregory Keough owe anything to the SEC?
No. On 6 October 2026 the Securities and Exchange Commission confirmed in writing that his payment “fully satisfies” his financial obligations to the Commission and that his file is closed and marked as fully paid. More than
Was Gregory Keough’s restitution paid?
0 million has been paid under the 2021 Order. Source: SEC letter of 6 October 2026.
Does Gregory Keough owe anything to the United States?
No. Restitution is recorded as paid in full in the judgment, no forfeiture was taken from him, the special assessment was paid, and the SEC has confirmed his obligations to the Commission are fully satisfied.
Did Gregory Keough keep any of the money?
No. These were loans, not grants, and every dollar was repaid. By the government’s own account in its sentencing announcement, $309,555 of the loan proceeds went to Keough. He personally repaid $500,000 to the Small Business Administration on 19 December 2022, eight months before any charge was filed, more than the government says he received. The full restitution of
Was Gregory Keough’s restitution paid?
,922,355 was then paid before sentencing, and the judgment records it as paid in full. Nothing was forfeited from him and nothing is owed. The SEC matter ended the same way: the SEC created a fund to return money to investors, and on 6 October 2026 it confirmed in writing that Keough’s obligations under its Order are fully satisfied.
Were the companies real?
Yes. 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. The record also contains a discrepancy about one of them: the criminal complaint said NFH Partners took in approximately
Was Gregory Keough’s restitution paid?
1,910 over thirteen months, while the company’s 2018 federal tax return reported $476,475 and the government’s own bank records for the same account show $413,509.93 deposited in that period (Criminal Complaint, DE 3, para. 18; Form 1120-S, 2018; TD Bank statements, government production).
Did Gregory Keough serve in the CIA?
Yes. He served as a covert operations officer in the CIA’s Directorate of Operations and received the Intelligence Star. Forbes reported his CIA service in May 1999 (Zina Moukheiber, “Three Men and a Web Idea,” 17 May 1999). In its own sentencing filing the government wrote that it “commends the Defendant for his then commitment to the United States and for his acts which earned him the Intelligence Star.”
How much did Gregory Keough repay before charges were filed?
$500,000. As personal guarantor of the company’s loan, Gregory Keough paid the full $500,000 loan principal to the Small Business Administration on 19 December 2022, eight months before the criminal complaint was filed. The SBA records that loan as paid in full (SBA payment confirmation, 19 December 2022; counsel’s letter to the U.S. Attorney’s Office).
Was anything forfeited from Gregory Keough?
No. The United States filed notice on 15 May 2024 that it was not pursuing forfeiture against him (Notice on Forfeiture, DE 65, on CourtListener).
Who submitted the loan applications?
The co-defendant, an attorney who was the company’s General Counsel, admitted under oath in his signed factual basis that he submitted loan applications, including one in his capacity as General Counsel. The court-appointed bankruptcy trustee, an adverse witness testifying under oath in January 2023, said she had no evidence Gregory Keough prepared, reviewed, signed, submitted or had ever seen the loan documents (Menotte deposition, 18 January 2023; the co-defendant’s Stipulated Factual Basis, 11 October 2022). His signed factual basis also states that he provided the falsified bank statements submitted with a PPP application.
What did the company’s own staff say about the loans?
Under oath in the bankruptcy case in November 2021, before any criminal charge, the company’s office manager was asked who told her the company was applying for the pandemic loans. She named the attorney. She testified she knew nothing about the SBA disaster loan.
What sentence did Gregory Keough receive?
30 months, the bottom of the guideline range, after the government asked for 37. He had no prior criminal record. The prosecution’s own sentencing filing commended his CIA service and the acts that earned him the Intelligence Star.
What did the government say NFH Partners took in?
The criminal complaint said approximately $11,910 in gross receipts were deposited over thirteen months. The government’s own bank records for the same account show $413,509.93 deposited in that period, $310,509.93 of it from other companies and $103,000 in transfers from Keough’s own accounts, and the company’s 2018 federal tax return reported $476,475.
How was Gregory Keough treated before trial compared with his co-defendant?
Gregory Keough was arrested and held in jail for 28 days, then released on $3 million in bonds, six times the attorney’s, to six and a half months of home detention with a GPS monitor he paid for. The co-defendant attorney was released on a $500,000 bond with no home detention and no monitoring, and was free to travel anywhere in the continental United States (Bond orders in both cases).
Where does Gregory Keough live now?
After serving his sentence, he asked the court to let him return to his wife and children in El Salvador. The government opposed it. The United States Probation Office did not object, and the court granted it (Order, DE 76).
Who investigated the case?
The FBI in West Palm Beach. The co-defendant attorney’s father was an FBI Special Agent in Palm Beach County for three decades, retiring in 2001, and then headed the Palm Beach County State Attorney’s Office money-laundering task force.
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Primary documents
The documents behind this page, quoted at length with citations.
- Deposition of the bankruptcy trustee, Menotte v. Keough, 18 January 2023
- Stipulated Factual Basis of the co-defendant, 11 October 2022
- Judgment and Notice on Forfeiture, United States v. Keough, 2024
- SEC order, Blockchain Credit Partners d/b/a DeFi Money Market, 6 August 2021
- Department of Justice press release on the sentencing, 9 February 2024
- Criminal Complaint, United States v. Keough, DE 3 (paras. 2 and 18)
- Bond orders: United States v. Keough, DE 28; the co-defendant’s case, DE 8
- Obituary, The Palm Beach Post, August 2008
Sources: Judgment DE 60 · Notice on Forfeiture DE 65 · Government’s sentencing response DE 57 · DE 73 · DE 76 · Menotte deposition, 18 Jan 2023 · co-defendant’s Stipulated Factual Basis, 11 October 2022 · GAO-18-203 · Criminal Complaint DE 3 · Bonds DE 26, DE 28, DE 29 (Keough), DE 8 (co-defendant) · SBA payment confirmation, 19 December 2022 · TD Bank statements, government production · Form 1120-S, 2018 · The Palm Beach Post, August 2008