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Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 1 of 7
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
`
`Holding a Criminal Term
`Grand Jury Sworn in on May 7, 2019
`
`UNITED STATES OF AMEzuCA
`
`EHH a/k/a Tian Yinyin,
`#*talwa Li Jiadong
`
`Criminal No.
`
`Count One: 18 U.S.C. s 1es6(h)
`(Conspiracy To Launder
`Monetary Instruments)
`
`Count Two: 18 U.S.C. $ 1960(a)
`(0perating an Unlicensed Money
`Transmitting Business)
`
`Forfeiture: 18 U.S.C. $ 982(a)(1);
`2l U.S.C. $ 8s3(p)
`
`The Grand Jury Charges:
`
`At times material to this Indictment:
`
`INDICTMENT
`
`INTRODUCTION
`
`l.
`
`The conduct alleged in this Indictment began outside of the jurisdiction ol any
`
`particular State or district, and later occurred within the District of Columbia and elsewhere, and
`
`was therefore within the venue of the United States District Court for the District of Columbia, as
`
`provided by Title I 8, United States Code, Sections 3237(a) and 3238.
`2.
`
`In late 2018, a virtual currency exchange ("The Exchange") had been hacked. The
`
`perpetrators of the hack stole nearly $250 million worth ofvirtual currencies.
`The hack and subsequent theft and laundering of funds involved nurnerous
`3.
`electronic communications made in furtherance of the scheme, including those described below'
`These communications include wire communications that transited through the United States.
`
`

`

`Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 2 of 7
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`4.
`
`Defendants EEH a/k/a Tian Yinyin and 4** a,4</a Li Jiadong were Chinese
`
`nationals that accessed the U.S. financial system.
`5.
`
`Tian Yinyin and Li Jiadong had virtual currency accounts at two virtual currency
`
`exchanges ("VCE-A" and "VCE-B"). At both VCE-A and VCE-B, Tian Yinyin and Li Jiadong
`
`used the registered usemames "snowsjohn" and "khaleesi," respectively.
`6.
`
`Between in or about July 2018 through in or about April 2019, Tian Yinyin and Li
`
`Jiadong engaged in $100,812,842.54 in cryptocurrency transactions, which primarily consisted of
`
`their exchange of virtual currency traceable to the hack of The Exchange. Tian Yinyin and Li
`
`Jiadong would convert such virtual currency into fiat currency and transfer it to customers, for a
`
`fee.
`
`7.
`
`Tian Yinyin's and Li Jiadong's virtual currency accounts at VCE-A were linked
`
`accounts. The accounts had significant transfers between each other and third-party accounts.
`8.
`
`Tian Yinyin linked a bank account at China Guangfa Bank ('CGB") to his VCE-A
`
`account less than a week after the intrusion and theft at The Exchange. This CGB account received
`
`approximately 491 deposits from VCE-A for 233,889,970 CYN (approximatety $34,504,173.43)
`
`and represents proceeds from Tian Yinyin's money laundering activities.
`9.
`The same CGB bank account was linked to Tian Yinyin's VCE-B account.
`10. Tian Yinyin's VCE-A and VCE-B accounts had no deposits for approximately two
`
`months prior to the hack ofThe Exchange.
`I 1. Tian Yinyin also had an account at vcE-c, a U.s.-based exchange, where he would
`sell BTC in exchange for prepaid Apple iTunes gift cards, a known method ofmoney laundering.
`12. Tian Yinyin's VCE-C advertisement stated that no ID was necessary for trades.
`
`2
`
`

`

`Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 3 of 7
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`13. On multiple occasions, Tian Yinyin, using his account at VCE-C, engaged in
`
`financial transactions to convert virtual cunency to U.S. dollars on behalfofhis customers in the
`
`United States.
`14. Li Jiadong transferred approximately 9.71443 BTC from his VCE-A and VCE-B
`
`accounts to Tian Yinyin's account at VCE-C.
`15. Tian Yinyin exchanged approximately $1,448,694.74 worth of BTC lor iTunes gift
`
`cards via 8,823 transactions from his account at VCE-C.
`16. Li Jiadong's advertisement on another virtual currency exchange ("VCE-D") noted
`
`that he was operating a professional business and gave his hours and payment information.
`17 . Li Jiadong linked bank accounts at nine Chinese banks-Agricultural Bank of
`
`China, China Everbright Bank, China CITIC Bank, CGB, China Minsheng Bank, Huaxia Bank,
`
`Industrial Bank, Pingan Bank, and Shanghai Pudong Development Bank-to his VCE-A account.
`
`These bank accounts received approximately 2,000 deposits from VCE-A for 229,282,960.97
`
`CYN (approximately $32,848,567.00) and represent proceeds from his money laundering
`
`activities.
`18. Tian Yinyin's VCE-B account sent approximatety 25 BTC (approximately
`
`$175,000) to Li Jiadong's VCE-A account.
`19. Tian Yinyin and Li Jiadong exchanged 2,165.39 BTC (approximately
`
`$15,529,934.00) between each other via VCE-A.
`20. Federal law required money transmitting businesses to be registered with the
`Financial Crimes Enforcement Network ("FinCEN"), which is located in the District of Columbia.
`
`The failure to register with FinCEN was a federal felony offense'
`
`-)
`
`

`

`Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 4 of 7
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`21. Federal law barred money transmitting businesses from transmitting funds that
`
`were known to be derived from a criminal offense or intended to be used to promote unla*fi.rl
`
`activity.
`22. At all relevant times, Tian Yinyin and Li Jiadong were not registered with FinCEN.
`
`COUNT ONE
`(Conspiracy To Launder Monetary Instruments)
`23. The allegations set forth in paragraphs I through 22 ofthis Indictment are re-alleged
`
`and incorporated by reference herein.
`24. From in or about 2018 through in or about April 2019, in the District ofColumbia
`
`and elsewhere, TIAN YINYIN, LI JIADONG, and co-conspirators known and unknown to the
`
`Grand Jury, conspired with each other and with others known and unknown to the Grand Jury to
`
`violate:
`
`a. Title 18, United States Code, Section 1956(a)(1)(AXi), that is, by
`
`conducting financial transactions which in fact involved the proceeds of
`
`specified unlawful activity, to wit, violations of: section 1343 (relating to
`
`wire fraud) and section 1960 (relating to illegal money transmitters),
`knowing that the property involved in such financial transactions
`
`represented the proceeds of some form of unlawful activity, with the intent
`
`to promote the carrying on of said specified unlawful activity;
`b. Title 18, United States Code, Section 1956(a)(1)(A)(i), that is, by
`
`conducting financial transactions which in fact involved the proceeds of
`
`specified unlawful activity, to wit, violations of: section 1343 (relating to
`
`wire fraud) and section 1960 (relating to illegal money transmitters),
`knowing that the property involved in such financial transactions
`
`4
`
`

`

`Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 5 of 7
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`represented the proceeds of some form of unla*{ul activity, and knowing
`
`that the transactions were designed in whole or in part to conceal or disguise
`
`the nature, the location, the source, the ownership, or the control oi the
`
`proceeds of said specified unlauful activity; and
`
`c.
`
`Title I 8, United States Code, Section 1956(a)(2)(A), that is, by transporting,
`
`transmitting, and transferring, or attempting to transport, transmit, and
`
`ransfer monetary instruments and funds from places outside of the United
`
`States to and through a place inside the United States, and from a place in
`
`the United States to or though a place outside the United States, with the
`
`intent to promote the carrying on of specified unlawful activity, to wit,
`
`violations of: section 1343 (relating to wire fraud) and section 1960 (relating
`
`to illegal money transmitters).
`25. It was the goal of the conspiracy for the defendants and other co-conspirators to
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`unlawfully enrich themselves by: exchanging bitcoin for fiat currency; operating a bitcoin money
`
`laundering service that did not collect sufficient data on its customers; and operating an illegal
`
`money transmission service.
`
`(Conspiracy To Launder Monetary Instruments, in violation of
`Title 18, United States Code, Section 1956(h))
`
`COUNT TWO
`(Operating an Unlicensed Money Transmitting Business)
`26. The allegations set forth in paragraphs 1 through 22 ofthis Indictment are re-alleged
`
`and incorporated by reference herein.
`27 . From in or about 2018 through in or about April 2019, in the District of Columbia
`
`and elsewhere, TIAN YINYIN and LI JIADONG knowingly conducted, controlled, managed,
`
`5
`
`

`

`Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 6 of 7
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`supervised, directed, and owned an unlicensed money transmitting business, as that term is defined
`
`in Title 18, United States Code, Section 1960(bXl), affecting interstate or foreign commerce, and
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`which:
`
`a.
`
`Failed to comply with the money transmitting business registration
`
`requirements under Title 31, United States Code, Section 5330, and the
`
`regulations prescribed thereunder; and
`
`b.
`
`Otherwise involved the transportation and transmission of funds known to
`
`TIAN YINYIN and LI JIADONG to have been derived from a criminal
`
`offense and intended to be used to promote and support unlawful activity;
`
`in violation of Title 1 8, United States Code, Section 1960(a).
`
`(Operating an Unlicensed Money Transmitting Business, in violation of Title 18,
`United States Code, Section 1960(a))
`
`FORFEITURE ALLEGATION
`
`l.
`
`Upon conviction of the offenses alleged in Counts One and Two, the defendant
`
`shall forfeit to the United States any property, real or personal, involved in the offense, and any
`
`property traceable thereto, pursuant to Title 18, United States Code, Section 982(a)(1). The United
`
`States will also seek a forfeiture money judgment for a sum of money equal to the value of any
`
`property, real or personal, involved in Counts One and Two, and any property traceable thereto.
`2.
`
`If any of the property described above, as a result of any act or omission of the
`
`defendant:
`
`a.
`b.
`c.
`d.
`
`cannot be located upon the exercise of due diligence;
`has been transferred or sold to, or deposited with, a third party;
`has been placed beyond thejurisdiction of the court;
`has been substantially diminished in value; or
`has been commingled with other property which cannot be divided without
`difficulty,
`
`6
`
`

`

`Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 7 of 7
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`the defendant shall forfeit to the United States any other property ofthe defendant, up to the value
`
`of the property described above, pursuant to Title 21, United States Code, Section 853(p).
`
`(Criminal Forfeiture, pursuant to Title 18, United States Code, Section 982(a)(1);
`and Title 21, United States Code, Section 853(p))
`
`A TRUE BILL:
`
`FOREPERSON.
`
`$. 5L
`
`SIN
`UNITED ST
`RNEY OF
`AND FOR THE DISTRICT OF COLUMBIA
`
`7
`
`

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