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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
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`Holding a Criminal Term
`Grand Jury Sworn in on May 7, 2019
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`UNITED STATES OF AMEzuCA
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`EHH a/k/a Tian Yinyin,
`#*talwa Li Jiadong
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`Criminal No.
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`Count One: 18 U.S.C. s 1es6(h)
`(Conspiracy To Launder
`Monetary Instruments)
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`Count Two: 18 U.S.C. $ 1960(a)
`(0perating an Unlicensed Money
`Transmitting Business)
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`Forfeiture: 18 U.S.C. $ 982(a)(1);
`2l U.S.C. $ 8s3(p)
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`The Grand Jury Charges:
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`At times material to this Indictment:
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`INDICTMENT
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`INTRODUCTION
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`l.
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`The conduct alleged in this Indictment began outside of the jurisdiction ol any
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`particular State or district, and later occurred within the District of Columbia and elsewhere, and
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`was therefore within the venue of the United States District Court for the District of Columbia, as
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`provided by Title I 8, United States Code, Sections 3237(a) and 3238.
`2.
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`In late 2018, a virtual currency exchange ("The Exchange") had been hacked. The
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`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.
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`Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 2 of 7
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`4.
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`Defendants EEH a/k/a Tian Yinyin and 4** a,4</a Li Jiadong were Chinese
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`nationals that accessed the U.S. financial system.
`5.
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`Tian Yinyin and Li Jiadong had virtual currency accounts at two virtual currency
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`exchanges ("VCE-A" and "VCE-B"). At both VCE-A and VCE-B, Tian Yinyin and Li Jiadong
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`used the registered usemames "snowsjohn" and "khaleesi," respectively.
`6.
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`Between in or about July 2018 through in or about April 2019, Tian Yinyin and Li
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`Jiadong engaged in $100,812,842.54 in cryptocurrency transactions, which primarily consisted of
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`their exchange of virtual currency traceable to the hack of The Exchange. Tian Yinyin and Li
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`Jiadong would convert such virtual currency into fiat currency and transfer it to customers, for a
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`fee.
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`7.
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`Tian Yinyin's and Li Jiadong's virtual currency accounts at VCE-A were linked
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`accounts. The accounts had significant transfers between each other and third-party accounts.
`8.
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`Tian Yinyin linked a bank account at China Guangfa Bank ('CGB") to his VCE-A
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`account less than a week after the intrusion and theft at The Exchange. This CGB account received
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`approximately 491 deposits from VCE-A for 233,889,970 CYN (approximatety $34,504,173.43)
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`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
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`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.
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`2
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`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
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`financial transactions to convert virtual cunency to U.S. dollars on behalfofhis customers in the
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`United States.
`14. Li Jiadong transferred approximately 9.71443 BTC from his VCE-A and VCE-B
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`accounts to Tian Yinyin's account at VCE-C.
`15. Tian Yinyin exchanged approximately $1,448,694.74 worth of BTC lor iTunes gift
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`cards via 8,823 transactions from his account at VCE-C.
`16. Li Jiadong's advertisement on another virtual currency exchange ("VCE-D") noted
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`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
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`China, China Everbright Bank, China CITIC Bank, CGB, China Minsheng Bank, Huaxia Bank,
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`Industrial Bank, Pingan Bank, and Shanghai Pudong Development Bank-to his VCE-A account.
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`These bank accounts received approximately 2,000 deposits from VCE-A for 229,282,960.97
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`CYN (approximately $32,848,567.00) and represent proceeds from his money laundering
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`activities.
`18. Tian Yinyin's VCE-B account sent approximatety 25 BTC (approximately
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`$175,000) to Li Jiadong's VCE-A account.
`19. Tian Yinyin and Li Jiadong exchanged 2,165.39 BTC (approximately
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`$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.
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`The failure to register with FinCEN was a federal felony offense'
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`-)
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`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
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`were known to be derived from a criminal offense or intended to be used to promote unla*fi.rl
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`activity.
`22. At all relevant times, Tian Yinyin and Li Jiadong were not registered with FinCEN.
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`COUNT ONE
`(Conspiracy To Launder Monetary Instruments)
`23. The allegations set forth in paragraphs I through 22 ofthis Indictment are re-alleged
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`and incorporated by reference herein.
`24. From in or about 2018 through in or about April 2019, in the District ofColumbia
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`and elsewhere, TIAN YINYIN, LI JIADONG, and co-conspirators known and unknown to the
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`Grand Jury, conspired with each other and with others known and unknown to the Grand Jury to
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`violate:
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`a. Title 18, United States Code, Section 1956(a)(1)(AXi), that is, by
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`conducting financial transactions which in fact involved the proceeds of
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`specified unlawful activity, to wit, violations of: section 1343 (relating to
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`wire fraud) and section 1960 (relating to illegal money transmitters),
`knowing that the property involved in such financial transactions
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`represented the proceeds of some form of unlawful activity, with the intent
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`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
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`conducting financial transactions which in fact involved the proceeds of
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`specified unlawful activity, to wit, violations of: section 1343 (relating to
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`wire fraud) and section 1960 (relating to illegal money transmitters),
`knowing that the property involved in such financial transactions
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`4
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`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
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`that the transactions were designed in whole or in part to conceal or disguise
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`the nature, the location, the source, the ownership, or the control oi the
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`proceeds of said specified unlauful activity; and
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`c.
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`Title I 8, United States Code, Section 1956(a)(2)(A), that is, by transporting,
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`transmitting, and transferring, or attempting to transport, transmit, and
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`ransfer monetary instruments and funds from places outside of the United
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`States to and through a place inside the United States, and from a place in
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`the United States to or though a place outside the United States, with the
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`intent to promote the carrying on of specified unlawful activity, to wit,
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`violations of: section 1343 (relating to wire fraud) and section 1960 (relating
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`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
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`laundering service that did not collect sufficient data on its customers; and operating an illegal
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`money transmission service.
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`(Conspiracy To Launder Monetary Instruments, in violation of
`Title 18, United States Code, Section 1956(h))
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`COUNT TWO
`(Operating an Unlicensed Money Transmitting Business)
`26. The allegations set forth in paragraphs 1 through 22 ofthis Indictment are re-alleged
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`and incorporated by reference herein.
`27 . From in or about 2018 through in or about April 2019, in the District of Columbia
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`and elsewhere, TIAN YINYIN and LI JIADONG knowingly conducted, controlled, managed,
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`5
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`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
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`in Title 18, United States Code, Section 1960(bXl), affecting interstate or foreign commerce, and
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`which:
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`a.
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`Failed to comply with the money transmitting business registration
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`requirements under Title 31, United States Code, Section 5330, and the
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`regulations prescribed thereunder; and
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`b.
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`Otherwise involved the transportation and transmission of funds known to
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`TIAN YINYIN and LI JIADONG to have been derived from a criminal
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`offense and intended to be used to promote and support unlawful activity;
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`in violation of Title 1 8, United States Code, Section 1960(a).
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`(Operating an Unlicensed Money Transmitting Business, in violation of Title 18,
`United States Code, Section 1960(a))
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`FORFEITURE ALLEGATION
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`l.
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`Upon conviction of the offenses alleged in Counts One and Two, the defendant
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`shall forfeit to the United States any property, real or personal, involved in the offense, and any
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`property traceable thereto, pursuant to Title 18, United States Code, Section 982(a)(1). The United
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`States will also seek a forfeiture money judgment for a sum of money equal to the value of any
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`property, real or personal, involved in Counts One and Two, and any property traceable thereto.
`2.
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`If any of the property described above, as a result of any act or omission of the
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`defendant:
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`a.
`b.
`c.
`d.
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`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,
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`6
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`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
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`of the property described above, pursuant to Title 21, United States Code, Section 853(p).
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`(Criminal Forfeiture, pursuant to Title 18, United States Code, Section 982(a)(1);
`and Title 21, United States Code, Section 853(p))
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`A TRUE BILL:
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`FOREPERSON.
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`$. 5L
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`SIN
`UNITED ST
`RNEY OF
`AND FOR THE DISTRICT OF COLUMBIA
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`7
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