`
`OR\GlNAL
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMERICA
`
`X
`
`INDICTMENT
`
`- v. -
`
`VIRGIL GRIFFITH,
`
`Defendant.
`
`20 Cr.
`
`2()CRIM
`
`615
`
`X
`
`COUNT ONE
`(Conspiracy to Violate the
`International Emergency Economic Powers Act)
`
`The Grand Jury charges:
`
`1.
`
`From at least in or about August 2018, up to and
`
`including in or about November 2019, in the Southern District of
`
`New York, the Democratic People's Republic of Korea ("DPRK"),
`
`and elsewhere outside of the jurisdiction of any particular
`
`State or district of the United States, VIRGIL GRIFFITH, the
`
`defendant, and others known and unknown, at least one of whom is
`
`expected to be first brought to and arrested in the Southern
`
`District of New York, knowingly and willfully did combine,
`
`conspire, confederate, and agree together and with each other to
`
`violate licenses, orders, regulations, and prohibitions in and
`
`issued under the International Emergency Economic Powers Act
`
`("IEEPA"), codified at Title 50, United States Code, Sections
`
`
`
`Case 1:20-cr-00015-PKC Document 9 Filed 01/07/20 Page 2 of 5
`
`1701-1706.
`
`2.
`
`It was a part and an object of the conspiracy that
`
`VIRGIL GRIFFITH, the defendant, and others known and unknown,
`
`would and did provide and cause others to provide services to
`
`the DPRK, without first obtaining the required approval of the
`
`U.S. Treasury Department's Office of Foreign Asset Control
`
`("OFAC"), in violation of 50 U.S.C. § 1705(a), 31 C.F.R. §§
`
`510.206(a), 510.212(b), and Executive Orders 13466 and 13722.
`
`3.
`
`It was further a part and an object of the conspiracy
`
`that VIRGIL GRIFFITH, the defendant, and others known and
`
`unknown, would and did evade and avoid, and attempt to evade and
`
`avoid, the requirements of U.S. law with respect to the
`
`provision of services .to the DPRK, in violation of 50 U.S.C. §
`
`1705(a), 31 C.F.R. §§ 510.212(a)-(b), and Executive Orders 13466
`
`and 13722.
`
`(Title 50, United States Code, Section 1705;
`Executive Orders 13466 and 13722;
`Title 18, United States Code, Section 3238.)
`
`2
`
`.
`
`
`
`•'
`
`Case 1:20-cr-00015-PKC Document 9 Filed 01/07/20 Page 3 of 5
`
`FORFEITURE ALLEGATION
`
`4.
`
`As a result of committing the offense alleged in Count
`
`One of this Indictment, VIRGIL GRIFFITH,
`
`the defendant, shall
`
`forfeit to the United States, pursuant to Title 18, United States
`
`Code, Section 981(a) (1) (C) and Title 28 United States Code, Section
`
`2461, any and all property, real and personal, that constitutes or
`
`is derived from proceeds traceable to the commission of said
`
`offense, including but not limited to a sum of money in United
`
`States currency representing the amount of proceeds traceable to
`
`the commission of said offense that the defendant personally
`
`obtained.
`
`Substitute Assets Provision
`
`5.
`
`If any of the above-described forfeitable property, as
`
`a result of any act or omission of the defendant:
`
`a.
`
`cannot be
`
`located upon
`
`the exercise of due
`
`diligence;
`
`b.
`
`has been transferred or sold to, or deposited with,
`
`a third person;
`
`c.
`
`has been placed beyond the jurisdiction of the
`
`Court;
`
`d.
`
`has been substantially diminished in value; or
`
`3
`
`
`
`Case 1:20-cr-00015-PKC Document 9 Filed 01/07/20 Page 4 of 5
`
`e.
`
`has been commingled with other property which
`
`cannot be subdivided without difficulty;
`
`it is the intent of the United States, pursuant to Title 21, United
`
`States Code, Section
`
`853(p) and Title 28, United States Code,
`
`Section 2461(c), to seek forfeiture of any other property of the
`
`defendant up to the value of the above forfeitable property.
`
`(Title 18, United States Code, Section 981;
`Title 21, United States Code, Section 853; and
`Title 28, United States Code, Section 2461.)
`
`er;~.,; ;&n..c,,,.,
`
`GEOFlfF:: BERMAN
`United States Attorney
`
`4
`
`
`
`Case 1:20-cr-00015-PKC Document 9 Filed 01/07/20 Page 5 of 5
`
`Form No. USA-33s-274 (Ed. 9-25-58)
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMERICA
`
`V.
`
`VIRGIL GRIFFITH
`
`Defendant.
`
`INDICTMENT
`
`20 Cr.
`
`(50 u.s.c. § 1705;
`~xecutive Orders 13466 and 13722;
`18 u.s.c. § 3238.)
`
`GEOFFREY S. BERMAN
`United States
`
`c:so.~ 7✓ iow
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`3~ &s\~{. o.s.~-s-~~ ~
`
`
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