The U.S. Court of Appeals for the First Circuit upheld the criminal conviction of a man who filed fraudulent loans in order to obtain PPP funds during the pandemic and dismissed allegations that his counsel was ineffective.

The U.S. originally brought suit against Elijah Majak Buoi in the U.S. District Court for the District of Massachusetts, where he was indicted and convicted on four counts of wire fraud and one count of making false statements to a financial institution after applying for multiple Paycheck Protection Program (PPP) loans for his startup, Sosuda Tech LLC, at the beginning of the pandemic.