According to a summary in the superseding indictment, from October 2002 through September 2007, Akouavi Kpade Afolabi engaged in conspiracy to obtain fraudulent visas to have Togolese females enter into the US with the purpose of forced labor.  Akouavi Afolabi and her co-conspirators made use of “DV-1 Holder”. DV-1 visa is a diversity visa which allows the selected Togolese to stay in the US for one year. Those selected Togolese were eligible to apply for diversity visas for their immediate family members.  Akouavi Kpade Afolabi and another co-conspirator, Geoffry Kouevi, sought individuals with a type of visa which would allow the holders to bring spouses or children with them into the country as a “DV-1 Holder”. She would then solicit “DV-1 Holder” to falsely claims for non-relatives as family members. Kouevi taught the recruits to study facts about their fake husbands and fathers in order to pass interviews at the U.S. Embassy, prepared all of the paperwork necessary for them to obtain their visas, and obtained fraudulent passports for them.

The operation, authorities say, targeted victims from impoverished African villages, some as young as 10. Akouavi Afolabi deceived victims and their families into believing that they could have a better life, for instance, having a good education at school. Akouavi Afolabi arranged and prepared recruiting, obtaining, and travelling to the US. After entering the US, Lassissi Afolabi (owner of Ashley’s Hair Braiding Salon), and Dereck Hounakey (owner of Newark Hair Braiding), both co-conspirators, took the victims to the residence in New Jersey. In order to control the victims, Akouavi Afolabi, Lassissi Afolabi, and Dereck Hounakey took possession of their passports, visas, and other travel documents .

Over the course of the conspiracy, Kouevi helped to fraudulently obtain more than 25 visas. Once the young women and girls entered the United States, Akouavi Kpade Afolabi, and her ex-husband required the victims to work at hair braiding salons for up to 14 hours per day, six to seven days a week. The victims were also required to turn over all of their earnings, including their tips, to the defendants. The defendants did not allow the girls to keep their passports or identification; to speak with their families outside of the defendants’ presence; or to make any outside friends. They were rarely permitted to leave their respective residence, all of which were controlled by the defendants, other than to work. When a victim broke a rule, she was punished, often physically, by one of the Afolabis.