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Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 1 of 22
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`--------------------------------- ----- - x
`
`UNITED STATES OF AMERICA
`
`-v.-
`
`ISHAN WAHI ,
`NIKHIL WAHI , and
`SAMEER RAMAN I ,
`
`Defendants .
`-------------------------------- - ------ x
`
`SEALED INDICTMENT
`
`22 Cr .
`
`2 2 CRIM 3 92
`
`.
`
`COUNT ONE
`(Conspiracy to Commit Wire Fraud)
`
`The Grand Jury charges :
`
`Overview of the Charges
`
`1 .
`
`From at least in or about June of 2021 through in or
`
`about April of 2022 ,
`
`ISHAN WAHI , NIKHIL WAHI , and SAMEER RAMANI ,
`
`the defendants , generated more than a million dollars in illegal
`
`trading profits through their participation in a scheme to
`
`engage in insider trading in crypto assets that were listed or
`
`were under considerat i on for listing on Coinbase Global , Inc .
`
`( "Coinbase" ) , a major online cryptocurrency exchange platform .
`
`As part of the insider trading scheme ,
`
`ISHAN WAHI violated his
`
`duties of trust and confidence to Coinbase by providing
`
`confidential business information that he learned in connection
`
`with his employment at Coinbase to NIKHIL WAHI and SAMEER RAMANI
`
`so that they could secretly engage in profitable trades around
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 2 of 22
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`public announcements by Coinbase that it would be listing
`
`certain crypto assets on Coinbase ' s exchanges .
`
`2 .
`
`ISHAN WAHI , the defendant , was a Coinbase employee
`
`involved in the highly confidential process of listing crypto
`
`assets on Coinbase ' s exchanges . As a result ,
`
`ISHAN WAHI had
`
`detailed and advanced knowledge of which crypto assets Coinbase
`
`was planning to list and the timing of public announcements
`
`about those listings . Because the market value of crypto assets
`
`typically significantly increased after Coinbase announced that
`
`it would be listing a particular asset on its exchanges ,
`
`Coinbase kept the information strictly confidential and
`
`prohibited its employees from sharing that information .
`
`In
`
`violation of these policies and his duties of trust and
`
`confidence to Coinbase ,
`
`ISHAN WAHI misappropriated that
`
`confidential business information to tip his brother , NIKHIL
`
`WAHI , the defendant , and ISHAN WAHI ' s friend and associate ,
`
`SAMEER RAMANI , the defendant , so that they could use that
`
`confidential information to make well - timed purchases of crypto
`
`assets in advance of Coinbase ' s listing announcements.
`
`3. After Coinbase ' s listing decisions became public , and
`
`after the crypto assets appreciated due to that announcement ,
`
`NIKHIL WAHI and SAMEER RAMANI , the defendants , caused the sale
`
`of those crypto assets for substantial profits .
`
`In total ,
`
`2
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 3 of 22
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`during the course of the scheme , NIKHIL WAHI and RAMANI
`
`collectively caused purchases of at least 25 crypto assets in
`
`advance of at least 14 separate Coinbase crypto asset listing
`
`announcements. As a result of the insider trading scheme ,
`
`NIKHIL WAHI and RAMANI collectively generated realized and
`
`unrealized gains totaling at least approximately $1 . 5 million.
`
`4.
`
`The defendants also took numerous steps to evade
`
`detection from law enforcement. Throughout their illegal
`
`trading , NIKHIL WAHI and SAMEER RAMANI , the defendants ,
`
`attempted to conceal their trading by transferring their crypto
`
`assets through a web of crypto accounts and anonymous Ethereum
`
`blockchain wallets , including through accounts held in others '
`
`names.
`
`In or about May 2022 , as the illegal insider trading
`
`scheme came to light ,
`
`ISHAN WAHI , the defendant , purchased a
`
`one-way airline ticket to a foreign country in an unsuccessful
`
`attempt to flee from the United States .
`
`Background
`
`5 .
`
`At all times relevant to this Indictment, Coinbase was
`
`one of the largest cryptocurrency exchanges in the world .
`
`Coinbase allowed users to acquire , exchange , and sell various
`
`crypto assets in online user accounts .
`
`In order to transact in
`
`a particular crypto asset on Coinbase , that crypto asset must be
`
`listed on Coinbase ' s exchanges.
`
`3
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 4 of 22
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`6 .
`
`During the time period relevant to this Indictment ,
`
`Coinbase frequently announced that particular crypto assets
`
`would be listed on one of its exchanges or were under
`
`consideration for listing. Coinbase often made these
`
`announcements on Coinbase ' s publicly available blog or Twitter
`
`account .
`
`It was well known that after Coinbase announced that
`
`it was going to be listing or was conside r ing listing a
`
`particular crypto asset , the market value of that crypto asset
`
`typically rose substantially .
`
`7.
`
`Because Coinbase viewed its reputation as a fair forum
`
`of exchange as essential to its business success , Coinbase took
`
`steps to guard the confidentiality of information regarding
`
`prospective asset listings and to ensure that potential traders
`
`did not learn of prospective listings before the company
`
`announced them formally to the general public . The company ' s
`
`policies and agreements thus prohibited employees from using
`
`confidential information about asset listings , including which
`
`crypto assets it intended to list on its exchanges , except for
`
`the benefit of Coinbase . Indeed , Coinbase ' s policies made clear
`
`that employees "helping to implement support of [a] new asset "
`
`were prohibited from " buy[ing] the new asset " in advance of an
`
`announcement . Coinbase ' s written policies also prohibited
`
`employees from disclosing the confidential information to any
`
`4
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 5 of 22
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`person outside of Coinbase , including "family or friends ," and
`
`expressly barred employees from providing a " tip" to any person
`
`who might make a trading decision based on the informati on.
`
`8 .
`
`Beginning in or about October 2020 ,
`
`ISHAN WAHI , the
`
`defendant , was emp lo yed by Coinbase as a product manager
`
`assigned to an asset listing team . Pursuant to the policies
`
`described above , and by virtue of his employment more generally ,
`
`ISHAN WAHI was prohibited from sharing confidential business
`
`information about Coinbase ' s asset listings with others and from
`
`using that information other than for the benefit of his
`
`employer. Moreover , as a member of Coinbase ' s asset listing
`
`team ,
`
`ISHAN WAHI was subject to an "enhanced trading policy "
`
`that , among other things , required him to report his digital
`
`asset holdings and seek preclearance for any digital asset
`
`trades conducted by ISHAN WAHI outside of Coinbase ' s platform .
`
`During the course o f his employment at Coinbase ,
`
`ISHAN WAHI
`
`provided Co inbase with a written certification that he had read
`
`the company ' s trading and confidentiality policies , that he
`
`understood them , and that he would comply with them .
`
`9.
`
`As a product manager on one of Coinbase ' s asset
`
`listing teams ,
`
`ISHAN WAHI , the defendant, frequently had
`
`advanced knowledge of which crypto assets Coinbase planned to
`
`announce it was listing or considering listing , and had advanced
`
`5
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 6 of 22
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`knowledge of the timing of those announcements.
`
`Indeed ,
`
`beginning at least in or about August 2021 and continuing until
`
`at least in or about May 2022 ,
`
`ISHAN WAHI was a member of a
`
`private messaging channel reserved for a small number of
`
`Coinbase employees with direct involvement in the Coinbase asset
`
`listing process . Upon joining the channel ,
`
`ISHAN WAHI was
`
`informed by another Coinbase employee that its purpose was to
`
`provide a " safe place to discuss details around asset launches"
`
`such as "exact announcement/ launch dates+ timelines " that the
`
`company did not wish to share with all of its employees .
`
`10 .
`
`ISHAN WAHI , the defendant , knew that the asset listing
`
`information discussed within the messaging channel was highly
`
`confidential or "need to know" and not to be shared outside what
`
`ISHAN WAHI himself referred to as the "tighter circle " of
`
`Coinbase employees involved in the asset listing .
`
`ISHAN WAHI
`
`also knew that due to the highly confidential nature of asset
`
`listing information , he and other Coinbase employees with access
`
`to the information we re prohibited from trading in assets under
`
`consideration for listing on Coinbase and tipping others so that
`
`they could trade on that information , no matter the forum in
`
`which the trading took place .
`
`11 .
`
`In connection with the scheme ,
`
`ISHAN WAHI , the
`
`defendant , sought to deceive Coinbase and his fellow employees
`
`6
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 7 of 22
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`by assuring them -
`
`through , among other means , Coinbase ' s
`
`private asset listing messaging channe l
`
`(including interstate
`
`wire communications sent from ISHAN WAHI to a fellow Coinbase
`
`employee located in Ma n hattan , New York) -
`
`that he was
`
`maintaining the confidential i ty of this information .
`
`In truth
`
`and in fact , however ,
`
`ISHAN WAHI repeatedly breached his duty of
`
`conf i dentiality to Coinbase by misappropriating Coinbase ' s
`
`confident i al information and providing i t to his brother , NIKH I L
`
`WAHI , the defendant , and ISHAN WAHI ' s friend and associate ,
`
`SAMEER RAMANI , the defendant , so that they could make profitable
`
`trades on the basis of that confidential information .
`
`The Insider Trading Scheme
`
`12 . On numerous occasions beginning at least in or about
`
`June 2021 and continuing through in or about April 2022 ,
`
`ISHAN
`
`WAHI , the defendant , knew in advance both that Coinbase planned
`
`to list particular crypto assets and when Coinbase intended to
`
`make its public announcements of those asset listings , and
`
`misappropriated this Co i nbase co n fidential information by
`
`providing i t to either NIKHIL WAHI or SAMEER RAMANI , the
`
`defendants , so that they could place profitable trades i n
`
`advance of Coinbase ' s public listing announcements . Upon
`
`learning Co i nbase ' s confidential listing plans , NI KHIL WAHI and
`
`SAMEER RAMAN I used anonymous Ethereum blockchain wallets to
`
`7
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 8 of 22
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`acquire certain crypto assets shortly before Coinbase publicly
`
`announced that it was listing or considering listing those same
`
`assets on its exchanges .
`
`13 . Based on conf idential information provided by ISHAN
`
`WAHI , the defendant , NIKHIL WAHI and SAMEER RAMANI,
`
`the
`
`defendants , collectively traded shortly in advance of at least
`
`14 separate Coinbase public listing announcements concerning at
`
`least 25 different crypto assets, and then , in most instances ,
`
`subsequently sold the crypto assets they had acquired for a
`
`profit . These trades collectively led to realized and
`
`unrealized gains totaling at least approximately $1.5 million .
`
`For example :
`
`Insider Trading in TRIBE
`
`a.
`
`In or about August 2021 , as a result of his
`
`employment at Coinbase ,
`
`ISHAN WAHI learned of Coinbase ' s
`
`intention to publicly announce that it was listing the crypto
`
`asset TRIBE on its exchanges . Because ISHAN WAHI was among a
`
`small group of Coinbase employees privy to Coinbase 's
`
`confidential listing plans , he had access to detailed and
`
`specific information regarding when Coinbase ' s public
`
`announcement that it was listing TRIBE would occur .
`
`In breach
`
`of his duty of confidentiality to Coinbase ,
`
`ISHAN WAHI tipped
`
`his brother , NIKHIL WAHI , about Coinbase ' s plan to list TRIBE .
`
`8
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 9 of 22
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`b . With advance knowledge of Coinbase's listing
`
`plans , on or about August 10 , 2021, NIKHIL WAHI caused an
`
`anonymous Ethereum blockchain wallet - which has since been
`
`linked to NIKHIL WAHI through internet protocol ("IP") address
`
`records and blockchain analysis -
`
`to purchase approximately
`
`$60 , 000 worth of TRIBE tokens. NIKHIL WAHI caused these
`
`purchases to be made in an anonymous Ethereum blockchain wallet
`
`mere minutes before Coinbase publicly announced that it would be
`
`listing TRIBE on its exchanges on August 10, 2021 . Following
`
`that announcement , the value of TRIBE increased substantially.
`
`The following day , NIKHIL WAHI , through multiple transactions,
`
`exchanged all of the TRIBE tokens for crypto stablecoins (each
`
`equivalent in value to 1 United States dollar) worth
`
`approximately $67,000, resulting in a profit of approximately
`
`$7,000 .
`
`Insider Trading in XYO
`
`c .
`
`In or about August 2021, as a result of his
`
`employment at Coinbase ,
`
`ISHAN WAHI learned of Coinbase ' s
`
`intention to publicly announce that it was listing the crypto
`
`asset XYO on its exchanges . Because ISHAN WAHI was among a
`
`small group of Coinbase employees privy to Coinbase ' s
`
`confidential listing plans , he had access to detailed and
`
`specific information regarding when Coinbase ' s public
`
`9
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 10 of 22
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`announcement that it was listing XYO would occur .
`
`In breach of
`
`his duty of confidentiality to Co i nbase ,
`
`ISHAN WAHI tipped his
`
`friend and associate , RAMANI , about Co i nbase ' s plan to list XYO .
`
`d . With advance knowledge of Coinbase ' s listing
`
`plans , between on or about August 31 , 2021 and on or about
`
`September 8 , 2021 , RAMANI caused a network of approximately 15
`
`separate anonymous Ethereum blockchain wallets - wh i ch have
`
`since been linked to RAMANI through either IP address records or
`
`blockchain ana l ysis -
`
`to purchase approximate l y $610 , 000 worth
`
`of XYO tokens . Fol l owing the September 8 , 2021 Co i nbase l i st i ng
`
`announcement , the value of XYO increased substantially .
`
`SAMEER
`
`RAMANI then caused the XYO tokens that he had acquired to be
`
`transferred to accounts he l d at a centralized exchange subject
`
`to his contro l. At the time of those transfers the assets had
`
`risen in value to be i ng worth approximately $1 . 5 million , and
`
`RAMANI had reaped ga i ns of nearly $900 , 000 .
`
`Insider Trading in ALCX, GALA, ENS , and POWR
`
`e .
`
`In or around November 2021 , as a result of his
`
`employment at Coinbase ,
`
`ISHAN WAHI lear n ed of Coinbase ' s
`
`intention to publicly announce that i t was listing the crypto
`
`assets ALCX , GALA , ENS , and POWR on its exchanges . Because
`
`ISHAN WAHI was among a small group of Coinbase employees privy
`
`to Coinbase ' s confidential listing plans , he had access to
`
`10
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 11 of 22
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`detailed and specific information regarding when Coinbase ' s
`
`public announcement that it was listing ALCX , GALA, ENS , and
`
`POWR would occur .
`
`In breach of his duty of confidentiality to
`
`Coinbase ,
`
`ISHAN WAHI tipped his brother , NIKHIL WAHI , about
`
`Coinbase ' s plan to list ALCX , GALA , ENS , and POWR.
`
`f. With advance knowledge of Coinbase ' s listing
`
`plans , on or about November 15 , 2021 , NIKHIL WAHI caused
`
`anonymous Ethereum blockchain wallets - which have since been
`
`linked to NIKHIL WAHI through IP address records and blockchain
`
`analysis -
`
`to purchase approximately $134 , 000 worth of ALCX ,
`
`GALA , ENS , and POWR tokens . NIKHIL WAHI caused certain of these
`
`purchases to be made in an anonymous Ethereum blockchain wallet
`
`mere minutes before Coinbase publicly announced that it would be
`
`listing ALCX, GALA , ENS , and POWR on its exchanges on November
`
`15 , 2021 . Following that November 15 , 2021 announcement , the
`
`value of certain of the tokens that NIKHIL WAHI had acquired
`
`increased substantially . NIKHIL WAHI then exchanged certain of
`
`the crypto tokens that he had acquired for stablecoins and
`
`transferred the remainder of the tokens and the stablecoin
`
`proceeds to accounts subject to his control . NIKHIL WAHI ' s
`
`trading collectively resulted in profits of approximately
`
`$13 , 000 .
`
`11
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 12 of 22
`
`Insider Trading Ahead of the April 2022 Announcement
`
`g .
`
`In or around April 2022 , as a result of his
`
`employment at Coinbase ,
`
`ISHAN WAHI learned of Coinbase ' s
`
`intention to publicly announce that it was considering
`
`potentially listing dozens of crypto assets on its exchanges .
`
`Because ISHAN WAHI was among a small group of Coinbase employees
`
`privy to Coinbase ' s confidential lis t ing plans , he had access to
`
`detailed and specific information regarding when Coinbase's
`
`public announcement that it was considering listing these
`
`various crypto tokens would occur .
`
`In breach of his duty of
`
`confidentiality to Coinbase ,
`
`ISHAN WAHI tipped his friend and
`
`associate , RAMANI , about Coinbase ' s plan to announce that
`
`certain crypto assets were under consideration for listing on
`
`Coinbase ' s exchanges.
`
`h . With advanced knowledge of Coinbase ' s listing
`
`plans , RAMANI caused multiple anonymous Ethereum blockchain
`
`wallets- which have since been linked to RAMANI through IP
`
`address records and blockchain analysis -
`
`to purchase large
`
`quantities of at least six of the crypto assets that were to be
`
`included in Coinbase ' s April 11 , 2022 listing announcement .
`
`RAMANI spent at least approximately $370 , 000 to acquire these
`
`crypto assets in advance o f the April 11 , 2022 announcement .
`
`Following Coinbase ' s Apr i l 11 , 2022 public announcement
`
`12
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 13 of 22
`
`regarding the crypto assets that were under consideration for
`
`listing , the crypto assets purchased by RAMANI quickly
`
`thereafter appreciated by over at l east over $195 , 000 .
`
`14 .
`
`To conceal their purchases of crypto assets in advance
`
`of Coinbase ' s listing announcements , NIKHIL WAHI and SAMEER
`
`RAMANI , the defendants , used accounts at centralized exchanges
`
`held in the names of others , and transferred funds , crypto
`
`assets , and proceeds of their scheme through multiple anonymous
`
`Ethereum blockchain wal l ets . NIKHIL WAHI and RAMANI also
`
`regularly created and used new Ethereum blockchain wallets
`
`without any prior transaction history in order to further
`
`conceal their involvement in the scheme .
`
`ISHAN WAHI ' s Attempt to Flee the United States
`
`15. Shortly after SAMEER RAMANI , the defendant , traded in
`
`advance of Coinbase ' s listing announcement on April 11 , 2022 , on
`
`or about April 12 , 2022 , a Twitter account that is well known in
`
`the crypto commun i ty , with hundreds of thousands of followers ,
`
`tweeted that it had identified an Ethereum blockchain wallet
`
`" that bought hundreds of thousands of dollars of tokens
`
`exclusively featured in the Coinbase Asset Listing post about 24
`
`hours before it was publ i shed ." The trading activity referenced
`
`in the April 12 , 2022 tweet was the trading caused by RAMANI on
`
`or about April 11 , 2022 . On April 13 , 2022 , Coinbase ' s Chief
`
`13
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 14 of 22
`
`Security Officer publicly replied on Twitter to the April 12 ,
`
`2022 tweet , and stated that Coinbase had already begun
`
`investigating the matter .
`
`16 . On or about April 28 , 2022 , Coinbase ' s Chief Executive
`
`Officer posted on the company ' s publicly accessible blog that
`
`the company was investigating whether " someone inside Coinbase"
`
`leaked the company ' s confidential information " to outsiders
`
`engaging in illegal activity ," and that any Coinbase employee
`
`who engaged in such activity would be "immediately terminated
`
`and referred to relevant authorities (potentially for criminal
`
`prosecution) ."
`
`17 . Less than two weeks later , on May 11 , 2022 , and in
`
`connection with Coinbase ' s investigation of leaked confidential
`
`information , the company ' s director of security operations
`
`emailed ISHAN WAHI , the defendant , to inform him that he should
`
`appear for an in - person meeting relating to Coinbase ' s asset
`
`listing process at Coinbase ' s Seattle , Washington office on May
`
`16 , 2022 .
`
`ISHAN WAHI confirmed he would attend the meeting .
`
`18. After learning that he was going to be interviewed as
`
`part of Coinbase ' s investigation ,
`
`ISHAN WAHI , the defendant ,
`
`attempted leave the United States and flee to India .
`
`Specifically , on the evening of Sunday , May 15 , 2022 , the night
`
`before his meeting with Coinbase was scheduled to occur ,
`
`ISHAN
`
`14
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 15 of 22
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`WAHI purchased a one-way ticket for a flight to New Delhi, India
`
`that was scheduled to depart approximately 11 hours later ,
`
`shortly before he was supposed to be interviewed by Coinbase .
`
`Prior to boarding the flight ,
`
`ISHAN WAHI falsely told Coinbase
`
`employees with whom he worked that he already had departed for
`
`India , when in truth and in fact he had not , claiming that he
`
`was "out indefinitely" and that his departure was due to a
`
`medical emergency involving his father. Approximately thirty(cid:173)
`
`five minutes before his scheduled departure time ,
`
`ISHAN WAHI
`
`wrote to Coinbase's director of security operations that he "had
`
`to fly back home" but that the meeting could be rescheduled to
`
`occur later in the week or early the next week.
`
`19 .
`
`In the hours between booking the one-way flight to
`
`India and his scheduled departure time on May 16 , 2022, ISHAN
`
`WAHI , the defendant , called and texted NIKHIL WAHI and SAMEER
`
`RAMANI, the defendants , about Coinbase ' s investigation, and sent
`
`both of them a photograph of the messages he had received on May
`
`11 , 2022 from Coinbase ' s director of security operations .
`
`20. Prior to boarding his May 16 , 2022, flight to India ,
`
`ISHAN WAHI , the defendant , was stopped by law enforcement agents
`
`and prevented from leaving the country . Despite his claims to
`
`Coinbase ' s director of security operations that he could
`
`reschedule his meeting for later that week or early the next
`
`15
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 16 of 22
`
`week ,
`
`ISHAN WAHI was traveling on a one - way ticket to India with
`
`an extensive array of belongings , including , among other items ,
`
`three large suitcases , seven electronic devices, two passports ,
`
`multiple other forms of identification , hundreds of dollars in
`
`U.S . currency, financial documents , and other personal effects
`
`and items .
`
`Statutory Allegations
`
`21 .
`
`From at least in or about July 2021 , up to and
`
`including in or about May 2022 , in the Southern District of New
`
`York , and elsewhere ,
`
`ISHAN WAHI and NIKHIL WAHI , the defendants,
`
`and others known and unknown , willfully and knowingly , did
`
`combine , conspire , confederate , and agree together and with each
`
`other to commit wire fraud , in violation of Title 18 , United
`
`States Code , Sections 1343 .
`
`22 .
`
`It was a part and object of the conspiracy that ISHAN
`
`WAHI and NIKHIL WAHI , the defendants , and others known and
`
`unknown , knowingly having devised and intending to devise a
`
`scheme and artifice to defraud and for obtaining money and
`
`property by means of false and fraudulent pretenses ,
`
`representations , and promises , would and did transmit and cause
`
`to be transmitted by means of wire and radio communication in
`
`interstate and foreign commerce, writings , signs , signals ,
`
`pictures , and sounds for the purpose of executing such scheme
`
`16
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 17 of 22
`
`and artifice , in violation of Title 18 , United States Code ,
`
`Section 1343 .
`
`(Title 18 , United States Code , Section 1349.)
`
`COUNT TWO
`(Conspiracy to Commit Wire Fraud)
`
`The Grand Jury further charges:
`
`23. The allegations contained in paragraphs 1 through 20
`
`of this Indictment are hereby repeated , re - alleged , and
`
`incorporated by reference as if fully set forth herein .
`
`24.
`
`From at least in or about June 2021 , up to and
`
`including in or about May 2022, in the Southern District of New
`
`York , and elsewhere ,
`
`ISHAN WAHI and SAMEER RAMANI , the
`
`defendants , and others known and unknown , willfully and
`
`knowingly , did combine , conspire , confederate , and agree
`
`together and with each other to commit wire fraud , in violation
`
`of Title 18 , United States Code , Sections 1343 .
`
`25.
`
`It was a part and object of the conspiracy that ISHAN
`
`WAHI and SAMEER RAMANI , the defendants , and others known and
`
`unknown , knowingly having devised and i ntending to devise a
`
`scheme and artifice to defraud and for obtaining money and
`
`property by means of false and fraudulent pretenses ,
`
`representations, and promises , would and did transmit and cause
`
`to be transmitted by means of wire and radio communication in
`
`interstate and foreign commerce , writings, signs , signals ,
`
`17
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 18 of 22
`
`pictures , and sounds for the purpose of executing such scheme
`
`and artifice , in violation of Title 18 , United States Code ,
`
`Section 1343 .
`
`(Title 18 , United States Code , Section 1349 . )
`
`COUNT THREE
`(Wire Fraud)
`
`The Grand Jury further charges:
`
`26 . The allegations contained in paragraphs 1 through 20
`
`of this Indictment are hereby repeated , re - alleged , and
`
`incorporated by reference as if fully set forth herein.
`
`27.
`
`From at least in or about July 2021 up to and
`
`including at least in or about May 2022 , in the Southern
`
`District of New York and elsewhere ,
`
`ISHAN WAHI and NIKHIL WAHI ,
`
`the defendants , knowingly having devised and intending to devise
`
`a scheme and artifice to defraud, and for obtaining money and
`
`property by means of false and fraudulent pretenses ,
`
`representations, and promises, transmitted and caused to be
`
`transmitted by means of wire and radio communication in
`
`interstate and foreign commerce, writings , signs , signals,
`
`pictures , and sounds , for the purpose of executing such scheme
`
`and artifice , to wit ,
`
`ISHAN WAHI and NIKHIL WAHI participated in
`
`a scheme to deprive Coinbase of its exclusive use of
`
`confidential business information related to Coinbase ' s plans to
`
`list certain crypto assets on its exchanges by converting that
`
`18
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 19 of 22
`
`information to their own use and relying on it to engage in
`
`profitable trades in crypto assets , in breach of ISHAN WAHI ' s
`
`duties of trust and confidence to Coinbase .
`
`(Title 18 , United States Code , Section 1343 and 2 . )
`
`COUNT FOUR
`(Wire Fraud)
`
`The Grand Jury further charges :
`
`28 . The allegations contained in paragraphs 1 through 20
`
`of this Indictment are hereby repeated, re-alleged , and
`
`incorporated by reference as if fully set forth herein .
`
`29.
`
`From at least in or about June 2021 up to and
`
`including at least in or about May 2022 , in the Southern
`
`District of New York and elsewhere, ISHAN WAHI and SAMEER
`
`RAMANI , the defendants , knowingly having devised and intending
`
`to devise a scheme and artifice to defraud , and for obtaining
`
`money and property by means of false and fraudulent pretenses ,
`
`representations , and promises, transmitted and caused to be
`
`transmitted by means of wire and radio communication in
`
`interstate and foreign commerce , writings , signs , signals ,
`
`pictures, and sounds , for the purpose of executing such scheme
`
`and artifice , to wit ,
`
`ISHAN WAHI and SAMEER RAMANI participated
`
`in a scheme to deprive Coinbase of its exclusive use of
`
`confidential business information related to Coinbase's plans to
`
`list certain crypto assets on its exchanges by converting that
`
`19
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 20 of 22
`
`information to their own use and relying on it to engage in
`
`profitable trades in crypto assets, in breach of ISHAN WAHI's
`
`duties of trust and confidence to Coinbase.
`
`(Ti tle 18, United States Code, Section 1343 and 2.)
`
`FORFEITURE ALLEGATION
`
`30 . As a result of committing one or more of the offenses
`
`alleged in Counts One through Four of this Indictment, ISHAN
`
`WAHI, NIKHIL WAHI, and SAMEER RAMANI,
`
`the defendants, 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 246l(c) , any and all property, real and personal,
`
`that constitutes or is derived from proceeds traceable to the
`
`commission of said offenses , including but not limited to a sum
`
`of money in United States currency representing the amount of
`
`proceeds traceable to the commission of said offenses.
`
`Substitute Assets Provision
`
`31 .
`
`If any of the above-described forfeitable property, as
`
`a result of any act or omission of ISHAN WAHI, NIKHIL WAHI, and
`
`SAMEER RAMANI,
`
`the defendants:
`
`(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 ;
`
`20
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 21 of 22
`
`(d) has been substantially diminished in value ; or
`
`(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 , to seek forfeiture of any other property of
`
`the defendants up to the value of the above forfeitable
`
`property.
`
`(Title 18, United States Code , Sections 981;
`Title 21 , United States Code, Section 853 ; and
`Title 28, United States Code , Section 2461 . )
`
`DAMIAN WILLIAMS
`United States Attorney
`
`21
`
`

`

`Case 1:22-cr-00392-LAP Document 1 Filed 07/19/22 Page 22 of 22
`
`Form No. USA-33s - 274 (Ed. 9-25 - 58)
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMERICA
`
`v.
`
`ISHAN WAHI,
`NIKHIL WAHI, and
`SAMEER RAMANI
`
`Defendants.
`
`SEALED INDICTMENT
`
`22 Cr .
`
`(18 u. s . c . ยงยง 1343 , 1349, & 2)
`
`DAMIAN WILLIAMS
`United States Attorney .
`
`A TRUE BILL
`
`~~5P:s: ~_, -
`
`Foreperson.
`
`'
`
`17ue ~,\\ + ~~d Tf\d,~c+[hP()+(cid:173)
`Qf'd 1 /10, )-zc befor'e ~
`re--
`
`

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