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 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 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 in the press releases
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 the court ordered
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 forfeited $1.6 million.
The federal government has received $4,337,974 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.
The two defendants, side by side
Both men were charged out of the same loan applications. The public record of each is set out below.
| Gregory Keough | The attorney | |
|---|---|---|
| Submitted and signed the loan applications | No. The bankruptcy trustee, an adverse witness, testified she had no evidence Keough prepared, reviewed, signed, submitted or had ever seen them. | Yes. Admitted under oath in his own signed factual basis, October 2022, including one application submitted in his capacity as General Counsel. |
| How each was charged | Indicted on eleven counts, August 2023. | Charged by negotiated Information on a single count, 27 September 2022, eleven months earlier. |
| Loan proceeds kept | The United States sought no forfeiture. | $869,682.83, taken as a forfeiture money judgment. |
| Paid to the Securities and Exchange Commission | $2,415,619.79, wired 31 March 2023. | Nothing as of 20 August 2026. |
| 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. |
| Recorded as paid to the United States | $2,415,619.79 wired to the Securities and Exchange Commission on 31 March 2023, and $1,922,355 restitution. The judgment records the restitution as paid in full, both before sentencing. | Nothing as of 20 August 2026. $4,337,991 remains outstanding to the Securities and Exchange Commission. |