Gregory Keough pleaded guilty in November 2023 to charges arising from 2020 pandemic-relief loans and served the sentence. Keough had already repaid the money before anyone charged him, restitution was paid in full before sentencing, and the government sought no forfeiture from 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.
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