{"id":"court_sdny_10_2","court":"SDNY","case_no":"","doc_number":10,"sub_number":null,"doc_type":"DOC","filed_date":null,"title":"SDNY ECF 10","summary_zh":null,"summary_en":null,"body_en":"CaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 1o fo 3f 838\nORIGINAL\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\nUNITED STATES OF AMERICA SEALED INDICTMENT\nV. 23 Cr.\nHO WAN KWOK,\na/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\"\na/k/a \"The Principal,\"\nKINMINGJE,\n...,\ni\n-~L ~u\na/k/a \"William Je,\"\nDefendants.\nCOUNT ONE\n(Conspiracy to Commit Wire Fraud, Securities Fraud, Bank Fraud, and\nMoney Laundering)\nThe Grand Jury charges:\nOverview\n1. From at least in or about 2018 through at least in or about March 2023, HO WAN\nKWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\"\na/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known\nand unknown, conspired to defraud thousands of victims of more than approximately $1 billion,\nincluding victims located in the Southern District of New York. KWOK, JE, and their\nco-conspirators operated through a series of complex fraudulent and fictitious businesses and\ninvestment opportunities that connected dozens of interrelated entities, which allowed the\ndefendants and their co-conspirators to solicit, launder, and misappropriate victim funds.\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 2o fo 3f 838\n2. HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the\ndefendants, and their co-conspirators, took advantage of KWOK's prolific online presence and\nhundreds of thousands of online followers to solicit investments in various entities and programs\nby promising outsized financial returns and other benefits. The entities and programs used in the\nscheme included those known as GTV, GICLUBS, GIMUSIC, GIFashion, and the Himalaya\nExchange, among others. In truth and in fact, and as KWOK and JE well knew, the entities were\ninstrumentalities that KWOK and JE created and used to perpetrate their fraud and exploit\nKWOK's followers. The scheme allowed KWOK and JE to enrich themselves, their family\nmembers, and their co-conspirators, and to fund KWOK's extravagant lifestyle.\n3. As part of the scheme, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a\n\"William Je,\" the defendants, and their co-conspirators, laundered hundreds of millions of dollars\nof fraud proceeds. To conceal the illegal source of the funds, KWOK and JE transferred, and\ndirected the transfer of, money into and through more than approximately 500 accounts held in the\nnames of at least 80 different entities or individuals. Hundreds of millions of dollars of the\nfraudulent scheme's proceeds were transferred, either directly or indirectly, to bank accounts in\nthe United States, Bahamas, and United Arab Emirates (\"UAE\"), among other places, and held in\nthe name of companies owned or otherwise controlled by JE.\n4. HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the\ndefendants, used more than approximately $300 million of the fraudulent scheme's proceeds for\ntheir and their families' benefit. For example, KWOK used fraudulently-obtained victim money\n2\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 3o fo 3f 838\nto purchase, fund, or finance a $26.5 million purchase of an approximately 50,000-square-foot\nmansion in New Jersey for KWOK and his family; luxury vehicles, including an approximately\n$3.5 million Ferrari for one of KWOK's close family members (\"Relative-I\"); an approximately\n$37 million luxury yacht that was used by KWOK and his family and purchased in the name of\none ofKWOK's close family members (\"Relative-2\"); a piano valued at approximately $140,000;\nan approximately $36,000 mattress; and a $100 million investment in a high-risk hedge fund for\nthe ultimate benefit of Relative-I, among other things. For his part, , among other things, JE\ntransferred at least $10 million of the fraud proceeds into his and his spouse's personal bank\naccounts.\n5. HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the\ndefendants, and their co-conspirators, operated the scheme for years, and continued to do so at\nleast through the date of this Indictment. They did so, among other things, by continually adapting\nthe scheme's means and methods to evade the enforcement of investor-protection, anti-money\nlaundering, and bankruptcy laws in the United States, and by retaliating against individual victims\nwho complained or demanded the return of invested funds.\nRelevant Persons and Entities\n6. At all relevant times, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant, was the leader\nof, and directed, the scheme.\na. KWOK is an exiled Chinese businessman who fled to the United States in\nor about 2015 and purchased a penthouse apartment at a New York City hotel for approximately\n$67.5 million. Starting at least in or about 2017, KWOK, who then purported to be a billionaire,\n3\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e4 4o fo 3f 838\n..\ngarnered a substantial online following. KWOK granted numerous media interviews and posted\non social media, claiming to advance a movement against the Chinese Communist Party.\nb. In or about 2018, KWOK founded two purported nonprofit organizations,\nnamely, the Rule of Law Foundation and the Rule of Law Society. The Rule of Law Society's\nwebsite lists KWOK as its \"founder, a promot[e]r, and a spokesperson.\" Both organizations\nfeature photographs of KWOK on their websites. KWOK used the nonprofit organizations to\namass followers who were aligned with his purported campaign against the Chinese Communist\nParty and who were also inclined to believe KWOK's statements regarding investment and money\nmaking opportunities. In truth and in fact, and as KWOK well knew, he and others provided false\nand materially misleading information to promote these \"opportunities\" and to defraud KWOK's\nfollowers and other victims.\n7. At all relevant times, KIN MING JE, a/k/a \"William Je,\" the defendant, was a dual\ncitizen of Hong Kong and the United Kingdom who principally resided in the United Kingdom,\nwhile traveling to the United States and elsewhere. JE owned and operated numerous companies\nand investment vehicles central to the scheme and served as its financial architect and key money\nlaunderer.\n8. At certain times relevant to this Indictment, Saraca Media Group, Inc. (\"Saraca\")\nwas a corporation based in New York, New York. Relative-I was its ultimate beneficial owner.\n9. At certain times relevant to this Indictment, GTV Media Group, Inc. (\"GTV\") was\na purported news-focused social media platform based in New York, New York. GTV was\nfunctionally owned and controlled by HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant, although\nKWOK held no formal position or title at GTV. KIN MING JE, a/k/a \"William Je,\" the defendant,\n4\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e5 5o fo 3f 838\nlikewise held no formal position or title at GTV, but in fact exercised control over its finances.\nSaraca was the parent company of GTV.\n10. At certain times relevant to this Indictment, G Club Operations, LLC (\"G[CLUBS\")\nwas a purported membership organization based in Puerto Rico and in New York, New York.\nG[CLUBS was functionally owned and controlled by HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant,\nalthough KWOK held no formal position or title at G[CLUBS. KIN MING JE, a/k/a \"William Je,\"\nthe defendant, likewise held no formal position or title at G[CLUBS, but in fact exercised control\nover its finances.\n11. At certain times relevant to this Indictment, the \"Himalaya Exchange\" was a\npurported cryptocurrency \"ecosystem\" that KIN MING JE, a/k/a \"William Je,\" the defendant,\nfounded and operated through various entities he owned, which were based abroad. Entities\nfunctionally owned and controlled by HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant, such as\nG[CLUBS and G[Fashion, had purported business relationships with the Himalaya Exchange.\nKWOK promoted the Himalaya Exchange and claimed to be the designer of its purported\ncryptocurrency, although KWOK held no formal position or title at the Himalaya Exchange.\nThe Fraud\nThe GTV Private Placement\n12. Between in or about April 2020 and in or about June 2020, HOWA N KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known and\n5\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e6 6o fo 3f 838\nunknown, fraudulently obtained more than $400 million in victim funds through an illegal private\nstock offering related to GTV (the \"GTV Private Placement\").\na. On or about April 21, 2020, KWOK posted, and caused to be posted, a video\non social media announcing the unregistered offering of GTV common stock via a private\nplacement. In that video, KWOK described, in substance and in part, the investment terms for the\nGTV Private Placement, and directed people to contact him, via a mobile messaging application,\nwith any questions about the GTV Private Placement. The video and GTV Private Placement\nmaterials-including the written \"Confidential Information Memorandum\" (the \"PPM\"),\nSubscription Agreement, and Investment Procedure Guidelines-were transmitted to thousands of\npotential investors, including those in the Southern District of New York, via mobile messaging\napplications, social media, and text messages.\nb. The PPM promoted GTV as the \"first ever platform which will combine the\npower of citizen journalism and social news with state-of-the-art technology, big data, artificial\nintelligence, block-chain technology and real-time interactive communication.\"\nc. According to the PPM' s metadata, JE was the \"author\" of the PPM. The\nPPM disclosed the terms of the GTV Private Placement and identified KWOK as GTV's \"Sponsor\nand Adviser.\" According to the PPM, among other GTV materials, neither KWOK nor JE held\nany formal management position with GTV.\nd. The PPM also contained the following representations, in substance and in\npart, among others:\nThe GTV Private Placement was for investors who were \"interested\n1.\nin evaluating an opportunity to invest capital into GTV;\"\n6\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e7 7o fo 3f 838\n11. GTV planned to use the proceeds raised from the GTV Private\nPlacement \"to expand and strengthen the business;\" and\niii. The PPM included a chart itemizing the \"contemplated use of\nproceeds\" raised from the GTV Private Placement:\nAcquisition of companies to strengthen and grow\nGTV\nUpgrade of GTV technology and security Approximate 10%\nMarketing Approximate 8%\nWorking capital Approximate 7%\nOther Approximate 5%\nTotal 100%\ne. Between on or about April 20, 2020 and on or about June 2, 2020,\napproximately $452 million worth ofGTV common stock was purportedly sold to more than 5,500\ninvestors located in the United States, including in the Southern District of New York, and abroad.\nInvestors participated in the GTV Private Placement based, in part, on the belief that their money\nwould be invested into GTV to develop and grow that business, as the PPM promised.\nf. The vast majority of the proceeds derived from investors in the GTV Private\nPlacement were not used to develop and grow the GTV business, but instead were deposited\ndirectly into bank accounts held in the name of Saraca, GTV's parent company, which is\nbeneficially owned by Relative-I.\ng. The GTV Private Placement was not made pursuant to a registration\nstatement filed with the U.S. Securities and Exchange Commission (\"SEC\"). Rather, the offering\n7\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e8 8o fo 3f 838\nwas purportedly made pursuant to SEC regulations that permit the sale of unregistered securities\nsubject to limitations on the type of investors to whom the securities are offered and the manner in\nwhich their investments may be solicited. To evade these limitations, however, KWOK, and others\nunder his control, used at least one intermediary entity to purchase GTV stock on behalf of pools\nof investors who did not qualify to participate in the GTV Private Placement.\nh. In or about early June 2020, and only days after the GTV Private Placement\nclosed, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a\n\"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants,\nand their co-conspirators, misappropriated approximately $100 million raised from investors in\nthe GTV Private Placement and directed that those funds be placed with a high-risk hedge fund\n(\"Fund-1 \") for the benefit of Saraca and its ultimate beneficial owner, Relative-I. This transaction\nwas contrary to the PPM's representations to prospective GTV investors about how investments\nin GTV would be used. Indeed, the $100 million investment into Fund-1 was not made for the\nbenefit of GTV, but rather for the benefit of Saraca. The victims who supplied the $100 million\ninvested into Fund-1 did not own any shares of Saraca. Ultimately, the investment into Fund-1\nlost approximately $30 million in value.\ni. After directing $100 million of GTV victim funds into Fund-1, HO WAN\nKWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\"\na/k/a \"The Principal,\" the defendant, continued to promote GTV using false and misleading\nrepresentations.\nThe Farm Loan Program\n13. Beginning in or about June 2020-the same month that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\n8\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e9 9o fo 3f 838\nPrincipal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and their co-conspirators\nmisappropriated money from the GTV Private Placement for the benefit of Saraca and\nRelative-I-KWOK, JE, and their co-conspirators fraudulently obtained more than approximately\n$150 million in victim funds through the \"Himalaya Farm Alliance.\" The Himalaya Farm\nAlliance, which KWOK organized and promoted, was a collective of informal groups ( each known\nas a \"Farm\") located in various cities around the world. KWOK, JE, and others working on their\nbehalf and at their direction, obtained these funds by making further misrepresentations to the\ninvestors in the GTV Private Placement and fraudulently soliciting further investments, this time\nin the form of \"loans\" to a Farm, and promising that such loans would be convertible into GTV\ncommon stock at a conversion rate of one share per dollar loaned (the \"Farm Loan Program\").\na. Starting in or about June 2020, domestic banks that held accounts used to\nprocess the funds raised through the GTV Private Placement began to freeze and close GTV\nassociated bank accounts because, among other reasons, the accounts had received dozens oflarge\nincoming wire transfers, some of which referenced an unregistered stock offering.\nb. These bank account closures frustrated the ability of KWOK, JE, and their\nco-conspirators to collect proceeds from victims seeking to invest in GTV.\nc. On or about July 22, 2020, in a video distributed via social media, KWOK\npromoted the Farm Loan Program. According to KWOK and those working on his behalf,\nindividuals seeking to invest (or reinvest) in GTV could participate in the Farm Loan Program.\nd. After launching the Farm Loan Program, KWOK continued to promote\nGTV and to falsely represent the value of GTV. For example, on or about August 2, 2020, in a\nvideo distributed via social media, KWOK falsely stated, in substance and part, \"How much is\n9\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 01 0o fo 3f 838\nGTV? .. . a market value of2 billion US dollars.\"1 In truth and in fact, and as KWOK well knew,\nGTV's market value was far less because, among other things, GTV was a new business that\ngenerated no revenue.\ne. Thousands of victims \"loaned\" money to the Farms by sending money to\nbank accounts controlled by the Farms (and not GTV). According to the \"Loan Agreements,\"\nwhich the Farms frequently did not countersign, these funds were to be used for a Farm's \"general\nworking capital purposes.\"\nf. KWOK and JE misappropriated funds that were raised through the Farm\nLoan Program. For example:\ni. Approximately $20 million was transferred to Relative-!,\napproximately $950,000 of which was used to pay for flight crew services on a private jet;\nii. Approximately $5 million was transferred to an entity owned by\nKWOK's spouse;\niii. Approximately $2.3 million was used to cover maintenance\nexpenses associated with an approximately 145-foot luxury yacht worth approximately $37\nmillion, nominally owned by Relative-2 and used by KWOK; and\niv. Approximately $10 million was transferred to personal bank\naccounts in the name of JE and/or JE's spouse.\nGICLUBS\n14. While making misrepresentations regarding the Farm Loan Program, HO WAN\nKWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\"\na/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known\n1 All statements attributed herein to KWOK have been translated from Mandarin to English,\nunless otherwise noted.\n10\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 11 1o fo 3f 838\nand unknown, fraudulently induced KWOK's followers to transfer additional funds to a purported\nonline membership club called GICLUBS. From at least in or about October 2020 through at least\nin or about March 2023, KWOK, JE, and others known and unknown, fraudulently obtained more\nthan approximately $250 million in victim funds through GICLUBS.\na. Starting at least on or about June 20, 2020, in a video distributed via social\nmedia, KWOK promoted and encouraged individuals to purchase what KWOK referred to as a\n\"G Club ... membership card.\"\nb. Formally launched in or about October 2020, GICLUBS claimed, on its\nwebsite, to be \"an exclusive, high-end membership program offering a full spectrum of services\"\nand \"a gateway to carefully curated world-class products, services and experiences.\"\nc. To join GICLUBS, a member was required to make a one-time payment to\npurchase a \"membership,\" in addition to an annual membership fee. The cost of the membership\nvaried based on the membership tier selected by the prospective member: Tier 5 Membership cost\n$50,000; Tier 4 Membership cost $40,000; Tier 3 Membership cost $30,000; Tier 2 Membership\ncost $20,000; and Tier 1 Membership cost $10,000.\nd. On or about July 5, 2021, in a video distributed via social media, KWOK\nstated, in substance and in part, that there were \"25,000 [GICLUBS] member[s] ... $100 million\ndollars, the cash [in] the bank account. Then we have the 111 million ... [who] want to join.\" By\ncontrast, GICLUBS internal documents reflected approximately 5,900 active members as of in or\nabout August 2021.\ne. In truth and in fact, and as KWOK and JE well knew, GICLUBS provided\nnothing close to \"a full spectrum of services\" and \"experiences\" to its members. Despite collecting\nhundreds of millions of dollars in purported membership fees, GI CLUBS maintained a relatively\n11\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 21 2o fo 3f 838\nsmall number of employees and provided its members few to no discernable membership benefits.\nIndeed, GICLUBS did not even make good on prizes it offered members for participating in\ncontests. On or about February 14, 2021, GICLUBS held a webcast and sweepstakes during which\nmembers were promised luxury prizes. On at least one occasion, instead of providing a BMW to\na member who purportedly won a sweepstakes, GIC LUBS claimed to the member that the member\nhad requested that the value of the BMW be applied toward an upgrade from a Tier 1 GIC LUBS\nMembership to a Tier 4 GICLUBS Membership and partially credited toward annual membership\nfees for the next three years. As of on or about March 8, 2021-months after GICLUBS launched\nand began to collect \"membership\" fees-GICLUBS did not have a business plan or a board of\ndirectors.\nf. KWOK and JE also used GICLUBS as a mechanism to continue fraudulent\nprivate placement offerings. KWOK, and others known and unknown, told KWOK's online\nfollowers that their purchase of GICLUBS memberships would entitle them to stock in KWOK\naffiliated entities, such as GTV and GIFashion.\ni. In a conversation regarding GICLUBS membership funds on or\nabout May 4, 2021, JE stated, in substance and in part, that \"first of all, [prospective members] are\nbuying the GICLUBS membership, but they are expecting they would probably receive some\nshares, you know, on, on, on the future GTV, I think this is their expectation.\"\nii. On or about July 30, 2021, KWOK stated in a video distributed via\nsocial media, in substance and in part, \"Some of the comrades in arms asked, '[w]ill I still get a\nfree stock offer when I buy a GICLUBS membership?' 100%. Because I said that I have to promise\nthat anyone who buys G-Club membership before September 17 must be allotted shares, which is\n12\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 31 3o fo 3f 838\nexactly the same. Because we said that anyone can choose whether to use your money to buy G\nClub before September 17, G-Club and the stock shares. You'll get both.\"\ng. KWOK, JE, and others known and unknown, asked investors to purchase\nmultiple memberships in GICLUBS, enabling KWOK and JE to increase the amount of money\nsolicited. In this regard, the GICLUBS website stated, in substance and in part, that members with\nmultiple memberships would \"receive additional benefits\" when, in truth and in fact, and as\nKWOK and JE well knew, multiple memberships did not provide members with additional\nbenefits.\n15. All told, investors purchased hundreds of millions of dollars' worth of GICLUBS\nmemberships. However, most of this money did not fund the business of GICLUBS. Rather, HO\nWAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother\nSeven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others\nknown and unknown, misappropriated a substantial portion of the funds victims had paid\nGICLUBS for \"memberships,\" using, among other things, a complex web of entities and bank\naccounts to do so. For example:\na. GICLUBS funds, which had been funneled through bank accounts in other\nentities' names, were used to pay personal expenses for KWOK and his family, including luxury\npurchases of an approximately $2.6 million yacht and luxury automobiles that together cost more\nthan $5 million.\nb. In or about November 2021, JE directed approximately $26.5 million of\nGICLUBS funds, which had been funneled through bank accounts in other entities' names, toward\nthe purchase ofKWOK's 50,000 square foot New Jersey mansion.\n13\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 41 4o fo 3f 838\nc. JE directed the transfer of an additional $13 million of GICLUBS\nmembership payments to an escrow account. The funds were subsequently used to pay for\nextravagant renovations to KWOK's New Jersey mansion, including to a wing for Relative-I and\nto a wing for Relative-2, and to purchase various furniture and decorative items including, among\nother items, Chinese and Persian rugs worth approximately $978,000, a $62,000 television, and\na $53,000 fireplace log cradle holder.\nd. On or about August 5, 2021, JE directed the transfer of approximately $1.1\nmillion consisting of GIC LUBS membership payments into a bank account that JE controlled.\ne. GIC LUBS used membership fees to purchase luxury automobiles, including\na custom-built Bugatti sports car for approximately $4.4 million. While the car's signed purchase\nagreement listed GICLUBS as the customer, the initial specifications documentation for the\ncustom-built car named Relative-I as the customer. Relative-I had no official position with\nGICLUBS.\nThe Himalaya Exchange\n16. From at least in or about April 2021 through at least in or about March 2023, HO\nWAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother\nSeven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others\nknown and unknown, fraudulently obtained more than approximately $262 million in victim funds\nthrough the Himalaya Exchange, a purported cryptocurrency \"ecosystem\" accessible on the\ninternet. The Himalaya Exchange included a purported stablecoin called the Himalaya Dollar\n(\"HDO\" or \"H Dollar\") and a trading coin called Himalaya Coin (\"HCN\" or \"H Coin\"). The\nHimalaya Exchange claimed that the \"stablecoin\" was a digital asset with a fixed 1-to-$1 value\n14\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 51 5o fo 3f 838\nbacked by reserves, and that the \"trading coin\" was a cryptocurrency with valuation based on\nsupply and demand. JE was the founder and Chairman of the Himalaya Exchange.\n17. In videos distributed via social media, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant,\ntrumpeted the prospects and valuation of the Himalaya Exchange and both HCN and HDO, which\nhe publicly described as cryptocurrencies. For example, in a video posted on the Internet on or\nabout October 20, 2021, KWOK falsely stated the following, among other things, and in substance\nand in part:\na. \"I am talking about your H Coins, 'Brother Seven' [i.e., KWOK] designed\nit ....[ l]t has the attribute of currency, why? It has 20% gold. Awesome[.] [I]t was born as\ncurrency on the first day, so it has value and it is linked to gold ... clear gold directly. No matter\nhow much it raises, 20% will tum into gold.\"\nb. \"If the H Coin is worthless, [the issuer of H coin] can sell all 20% of the\ngold, exchange it to you, and become your money. Or take all the value of 20% gold and ask\neveryone to unify it and make it yours.\"\nc. \"If anyone loses money, I can say that I will compensate 100%. I give you\n100%. Whoever loses money, I will bear it.\"\nd. \"I can sell the H Coin in the market in one minute and get it back to my\nH Dollar, and back to your fiat money unit. ... [A]nd you can buy anything immediately.\"\n18. The initial coin offering of HCN and HDO occurred on or about November 1, 2021.\nHCN began trading at 10 cents and, within approximately two weeks, the Himalaya Exchange\nwebsite claimed that each HCN purportedly was worth approximately 27 HDO (i.e., $27), which\nrepresented a 26,900% increase in value. That is, approximately two weeks after the initial coin\n15\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 61 6o fo 3f 838\noffering, the Himalaya Exchange website indicated that HCN purportedly had an approximately\n$27 billion valuation.\n19. At the time of the Himalaya Exchange launch, HO WAN KWOK, a/k/a \"Miles\nGuo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the\ndefendant, marketed HCN to his online followers and others. For example, on or about November\n1, 2021-the day of the initial coin offering-KWOK released an official music video for an\noriginal song called \"HCoin To the Moon\" via social media. The phrase \"to the moon\" is popularly\nassociated with cryptocurrencies and implies a sharp increase in value. The music video depicted\nKWOK in various luxurious locations and depicted imagery of gold and wealth.\n20. At times, including following the Himalaya Exchange launch, KIN MING JE, a/k/a\n\"William Je,\" the defendant, misleadingly marketed the Himalaya Exchange. For example, in or\nabout June 2022, JE attempted to create the impression that a €3,561, 127 purchase of a Ferrari (the\n\"Ferrari\") from a particular auction house was completed with HDO. JE stated, in substance and\nin part, that he was \"extremely pleased that [a] buyer decided to purchase [a] world-class car using\nHDO.\" Contrary to JE' s claim, the Ferrari was not purchased using HDO. In truth and in fact,\nand as JE well knew, a Himalaya Exchange employee sent the auction house an international bank\nwire to cover the cost of the Ferrari, while also processing a corresponding \"transaction\" on the\nHimalaya Exchange to create the false appearance that the purchase had taken place using HDO.\nJE's statement was also misleading in that, among other things, the unidentified \"buyer\" of the\nFerrari was, in fact, Relative-I.\n21. Contrary to representations of HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles\nKwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE,\na/k/a \"William Je,\" the defendants, and others known and unknown, HCN and HDO could not be\n16\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 71 7o fo 3f 838\ntraded anywhere other than (purportedly) on the Himalaya Exchange. Moreover, unlike\ncryptocurrencies, HCN could not be traded for, or converted into, other currencies. HCN\npurportedly could be traded for only HDO (and only on the Himalaya Exchange), and HDO\npurportedly only could be converted to or from fiat currency (and only on the Himalaya Exchange).\na. Indeed, the HDO and HCN Whitepapers, available on the Himalaya\nExchange website, provided in fine print that, contrary to KWOK's representations, HCN and\nHDO were not cryptocurrencies. Rather, according to the HCN Whitepaper, the \"operation of the\nHimalaya Exchange and associated applications and infrastructure will be facilitated through the\nuse of 'Credits.\"' Those credits (i) could \"only be used on the Himalaya Exchange or within the\nHimalaya Ecosystem,\" and (ii) did \"not carry any right to require their exchange for fiat currency\nor crypto-assets.\" Moreover, while Himalaya Exchange members could request to exchange their\n\"HDO\" credits for an equivalent payment in U.S. dollars, the HDO Whitepaper stated that the\nHimalaya Exchange had the \"discretion\" to deny any such request.\n22. In or about April 2022, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a\n\"William Je,\" the defendants, arranged for the transfer of approximately $37 million in Himalaya\nExchange funds from a Himalaya Exchange bank account to a particular escrow account. The $3 7\nmillion was structured as a purported \"loan\" to cover the cost of a luxury yacht that KWOK had\npreviously purchased and used, which yacht was then-owned by an entity held in the name of\nRelative-2.\nGovernment Seizure ofF raud Proceeds\n23. On or about September 20, 2022 and September 21, 2022, U.S. authorities served\njudicially-authorized seizure warrants on several domestic banks, and subsequently seized\n17\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 81 8o fo 3f 838\napproximately $335 million of proceeds from bank accounts held in the names of Himalaya\nExchange entities and other entities associated with HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING\nJE, a/k/a \"William Je,\" the defendants. Following the September 2022 judicially authorized\nseizures, JE attempted to transfer approximately $46 million from domestic bank accounts\nassociated with the Himalaya Exchange, which had not yet been seized by the United States, to a\nbank account in the UAE that JE controlled.\na. Within approximately two days of the first judicially authorized seizures of\nHimalaya Exchange-related funds, on or about September 22, 2022, JE contacted the management\nof a domestic bank that held Himalaya Exchange bank accounts. JE sought to implement a wire\ntransfer, which he and a Himalaya Exchange executive claimed to the domestic bank was needed\nto effectuate a \"redemption\" from HDO to U.S. dollars for an unnamed \"VIP\" (i.e., very important\nclient of the Himalaya Exchange).\nb. In subsequent communications with the domestic bank, JE revealed that the\nVIP was, in fact, JE himself. JE provided the domestic bank with documents reflecting two\npurported HCN sales by JE on or about September 22, 2022-totaling 46 million HDO, which JE\nwas attempting to \"convert\" into $46 million. JE twice emphasized to the domestic bank's\nmanagement, in substance and in part, that the $46 million transfer needed to happen \"today or it\nis meaningless.\"\n24. On or about October 16, 2022, pursuant to a judicially authorized warrant, U.S.\nauthorities seized an additional approximately $274 million of proceeds from several Himalaya\nExchange and GICLUBS accounts at the domestic bank from which JE requested the $46 million\ntransfer.\n18\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e1 91 9o fo 3f 838\na. As a result of the judicially authorized September and October 2022\nseizures, U.S. authorities seized more than approximately $609 million of fraud proceeds,\nincluding approximately $278 million from bank accounts held in the names of the Himalaya\nExchange entities, including accounts that purported to hold its HDO cash reserves.\nb. Following the seizures, the Himalaya Exchange website continued to\nrepresent that HDO was backed by a \"Reserve consisting of USD and cash-equivalent assets\"\nwhen, in truth and in fact, it was not.\nc. Despite the seizure of the Himalaya Exchange's cash reserves, the\npurported price ofHCN had not suddenly and sharply declined through the date of this Indictment.\nSTATUTORY ALLEGATIONS\n25. From at least in or about 2018 up to and including at least in or about March 2023,\nin the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING\nJE, a/k/a \"William Je,\" the defendants, and others known and unknown, willfully and knowingly\ncombined, conspired, confederated, and agreed together and with each other to commit offenses\nagainst the United States, to wit, (1) wire fraud, in violation of Title 18, United States Code, Section\n1343; (2) securities fraud, in violation of Title 15, United States Code, Sections 78j(b) & 78ff, and\nTitle 17, Code of Federal Regulations, Section 240.l0b-5; (3) bank fraud, in violation of Title 18,\nUnited States Code, Section 1344; (4) international promotional money laundering, in violation of\nTitle 18, United States Code, Section 1956(a)(2)(A); and (5) international concealment money\nlaundering, in violation of Title 18, United States Code Section 1956(a)(2)(B)(i).\n26. It was a part and an object of the conspiracy that HO WAN KWOK, a/k/a \"Miles\nGuo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\"\n19\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 02 0o fo 3f 838\nand KIN MING JE, a/k/a \"William Je,\" the defendants, and others known and unknown,\nknowingly having devised and intending to devise a scheme and artifice to defraud, and for\nobtaining money and property by means of false and fraudulent pretenses, representations, and\npromises, would and did transmit and cause to be transmitted by means of wire, radio, and\ntelevision communication in interstate and foreign commerce, writings, signs, signals, pictures,\nand sounds for the purpose of executing such scheme and artifice, in violation of Title 18, United\nStates Code, Section 1343, to wit, KWOK and JE agreed to obtain victims' money by causing\nmaterially false information and misrepresentations to be transmitted over interstate wires, in\nconnection with the GTV Private Placement, the Farm Loan Program, GICLUBS, and the\nHimalaya Exchange.\n27. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known and\nunknown, willfully and knowingly, directly and indirectly, by use of a means and instrumentality\nof interstate commerce and of the mails, and of a facility of a national securities exchange, used\nand employed, in connection with the purchase and sale of a security registered on a national\nsecurities exchange and any security not so registered, a manipulative and deceptive device and\ncontrivance, in violation of Title 17, Code of Federal Regulations, Section 240.l0b-5, by\n(a) employing a device, scheme and artifice to defraud; (b) making an untrue statement of material\nfact and omitting to state a material fact necessary in order to make the statement made, in light of\nthe circumstances under which it was made, not misleading; and ( c) engaging in an act, practice\nand course of business which operated and would operate as a fraud and deceit upon a person, to\nwit, KWOK and JE agreed to fraudulently induce investors to participate in the GTV Private\n20\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 12 1o fo 3f 838\nPlacement, the Farm Loan Program, and GICLUBS by providing materially false and misleading\ninformation and representations in connection with purported shares of GTV common stock and\npurported companies affiliated with GTV.\n28. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known and\nunknown, knowingly would and did execute and attempt to execute a scheme and artifice to\ndefraud a financial institution, as defined in Title 18, United States Code, Section 20, and to obtain\nmoneys, funds, credits, assets, securities, and other property owned by, and under the custody and\ncontrol of, such a financial institution, by means of false and fraudulent pretenses, representations,\nand promises, in violation of Title 18, United States Code, Section 1344, to wit, KWOK and JE\nagreed to participate in a scheme to mislead U.S. financial institutions through false and fraudulent\npretenses, representations, and documents, in connection with the GTV Private Placement, the\nFarm Loan Program, GICLUBS, and the Himalaya Exchange, in order to obtain money of, or under\nthe custody and control of, at least one financial institution.\n29. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known and\nunknown, would and did transport, transmit, and transfer, and attempt to transport, transmit, and\ntransfer, a monetary instrument and funds from a place in the United States to and through a place\noutside the United States, and to a place in the United States from and through a place outside the\nUnited States, with the intent to promote the carrying on specified unlawful activity, to wit, the\n21\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 22 2o fo 3f 838\noffenses alleged in Counts Two through Eight of this Indictment in violation of Title 18, United\nStates Code, Section 1956(a )(2)(A)(i).\n30. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known and\nunknown, would and did transport, transmit, and transfer, and attempted to transport, transmit, and\ntransfer, a monetary instrument and funds from a place in the United States to and through a place\noutside the United States, and to a place in the United States from and through a place outside the\nUnited States, knowing that the monetary instrument and funds involved in the transportation,\ntransmission, and transfer represent the proceeds of some form of unlawful activity, and knowing\nthat such transportation, transmission, and transfer is designed in whole and in part to conceal and\ndisguise the nature, location, source, ownership, and control of the proceeds of specified unlawful\nactivity, to wit, the offenses alleged in Counts Two through Eight of this Indictment, in violation\nof Title 18, United States Code, Section 1956(a)(2)(B)(i).\nOvert Acts\n31. In furtherance of the conspiracy and to effect its illegal objects, HO WAN KWOK,\na/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known and\nunknown, committed the following overt acts, among others, in the Southern District of New York\nand elsewhere:\na. On or about April 21, 2020, KWOK posted, and caused to be posted, a video\non social media announcing the unregistered offering of GTV stock via the GTV Private\nPlacement.\n22\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 32 3o fo 3f 838\nb. On or about June 5, 2020, a co-conspirator not named herein (\"CC-1 \"),\nwhile located in the Southern District of New York, authorized a wire transfer of $100 million\nfrom Saraca to Fund-1.\nc. On or about July 22, 2020, in a video distributed via social media, KWOK\npromoted the Farm Loan Program.\nd. On or about August 2, 2020, in a video distributed via social media, KWOK\nstated, in substance and part, \"How much is GTV? ... a market value of 2 billion US dollars.\"\ne. On or about May 28, 2021, JE transferred approximately $13 million from\na bank account in the UAE that JE controlled to a bank account held by an entity (owned by\nRelative-2) at a particular bank in New York, New York.\nf. On or about July 30, 2021, in a video distributed via social media, KWOK\nstated, in substance and in part, \"Some of the comrades in arms asked, ' [w ]ill I still get a free stock\noffer when I buy a G-Clubs membership?' 100%. Because I said that I have to promise that [to]\nanyone who buys G-Clubs membership before September 17 [they] must be allotted shares, which\nis exactly the same. Because we said that anyone can choose whether to use your money to buy\nG-Clubs before September 17, G-Clubs and the stock shares. You'll get both.\"\ng. On or about August 5, 2021, JE directed the transfer of approximately $1.1\nmillion consisting of funds victims had sent to G[CLUBS in exchange for \"memberships\" to a\nbank account that JE controlled.\nh. On or about October 20, 2021, in a video distributed via social media,\nKWOK stated, in substance and in part, that KWOK \"designed\" HCN, that \"[n]o matter how much\nit raises, 20% will tum into gold,\" and that \"[i]f anyone loses money\" on HCN, \"I can say that I\nwill compensate 100%.\"\n23\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 42 4o fo 3f 838\nOn or about September 22, 2022, JE texted a U.S. bank's management, in\n1.\nsubstance and in part, that a $46 million transfer to a JE-controlled bank account in the UAE\nneeded to happen \"today or it is meaningless.\"\n(Title 18, United States Code, Section 371.)\nCOUNT TWO\n(Wire Fraud - GTV Private Placement)\nThe Grand Jury further charges:\n32. The allegations contained m paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n33. From at least in or about April 2020 up to and including at least in or about March\n2021, in the Southern District of New York and elsewhere, HOWA N KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, knowingly having devised and intending to devise\na scheme and artifice to defraud, and for obtaining money and property by means of false and\nfraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by\nmeans of wire, radio, and television communication in interstate and foreign commerce, writings,\nsigns, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,\nKWOK and JE conducted the GTV Private Placement to sell GTV stock and fraudulently obtain\nmoney from victims through false statements and misrepresentations, which scheme was furthered\nthrough electronic communications and monetary transfers to and from the Southern District of\nNew York and elsewhere.\n(Title 18, United States Code, Sections 1343 and 2.)\n24\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 52 5o fo 3f 838\n•\nCOUNT THREE\n(Securities Fraud - GTV Private Placement)\nThe Grand Jury further charges:\n34. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n35. From at least in or about April 2020 up to and including at least in or about March\n2021, in the Southern District ofNew York, and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, willfully and knowingly, directly and indirectly, by\nuse of a means and instrumentality of interstate commerce and of the mails, and of a facility of a\nnational securities exchange, used and employed, in connection with the purchase and sale of a\nsecurity registered on a national securities exchange and any security not so registered, a\nmanipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal\nRegulations, Section 240.1 0b-5, by (a) employing a device, scheme and artifice to defraud;\n(b) making an untrue statement of material fact and omitting to state a material fact necessary in\norder to make the statement made, in light of the circumstances under which it was made, not\nmisleading; and ( c) engaging in an act, practice and course of business which operated and would\noperate as a fraud and deceit upon a person, to wit, KWOK and JE conducted the GTV Private\nPlacement to sell GTV stock and obtain money from victims through false statements and\nmisrepresentations, which scheme was furthered through electronic communications and monetary\ntransfers to and from the Southern District of New York and elsewhere.\n(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal Regulations,\nSection 240.l0b-5; and Title 18, United States Code, Section 2.)\n25\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 62 6o fo 3f 838\n•\nCOUNT FOUR\n(Wire Fraud - Farm Loan Program)\nThe Grand Jury further charges:\n36. The allegations contained m paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n37. From at least in or about June 2020 up to and including at least in or about March\n2023, in the Southern District of New York and elsewhere, HOWA N KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, knowingly having devised and intending to devise\na scheme and artifice to defraud, and for obtaining money and property by means of false and\nfraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by\nmeans of wire, radio, and television communication in interstate and foreign commerce, writings,\nsigns, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,\nKWOK and JE conducted the Farm Loan Program to fraudulently obtain money from victims\nthrough false statements and misrepresentations, which scheme was furthered through electronic\ncommunications and monetary transfers to and from the Southern District of New York and\nelsewhere.\n(Title 18, United States Code, Sections 1343 and 2.)\nCOUNT FIVE\n(Securities Fraud - Farm Loan Program)\nThe Grand Jury further charges:\n38. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n26\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 72 7o fo 3f 838\n..\n39. From at least in or about June 2020 up to and including at least in or about March\n2023, in the Southern District of New York, and elsewhere, HOWA N KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, willfully and knowingly, directly and indirectly, by\nuse of a means and instrumentality of interstate commerce and of the mails, and of a facility of a\nnational securities exchange, used and employed, in connection with the purchase and sale of a\nsecurity registered on a national securities exchange and any security not so registered, a\nmanipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal\nRegulations, Section 240.l0b-5, by (a) employing a device, scheme and artifice to defraud;\n(b) making an untrue statement of material fact and omitting to state a material fact necessary in\norder to make the statement made, in light of the circumstances under which it was made, not\nmisleading; and ( c) engaging in an act, practice and course of business which operated and would\noperate as a fraud and deceit upon a person, to wit, KWOK and JE conducted the Farm Loan\nProgram to obtain money from victims through false statements and misrepresentations, including\nregarding, among other things, the value of GTV, which scheme was furthered through electronic\ncommunications and monetary transfers to and from the Southern District of New York and\nelsewhere.\n(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal Regulations,\nSection 240.1 0b-5; and Title 18, United States Code, Section 2.)\nCOUNT SIX\n(Wire Fraud - GICLUBS)\nThe Grand Jury further charges:\n40. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n27\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 82 8o fo 3f 838\n41. From at least in or about June 2020 up to and including at least in or about March\n2023, in the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, knowingly having devised and intending to devise\na scheme and artifice to defraud, and for obtaining money and property by means of false and\nfraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by\nmeans of wire, radio, and television communication in interstate and foreign commerce, writings,\nsigns, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,\nKWOK and JE promoted and marketed GICLUBS to fraudulently obtain money from victims\nthrough false statements and misrepresentations, which scheme was furthered through electronic\ncommunications and monetary transfers to and from the Southern District of New York and\nelsewhere.\n(Title 18, United States Code, Sections 1343 and 2.)\nCOUNT SEVEN\n(Securities Fraud - GjCLUBS)\nThe Grand Jury further charges:\n42. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n43. From at least in or about June 2020 up to and including at least in or about March\n2021, in the Southern District ofNew York, and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, willfully and knowingly, directly and indirectly, by\nuse of a means and instrumentality of interstate commerce and of the mails, and of a facility of a\nnational securities exchange, used and employed, in connection with the purchase and sale of a\n28\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e2 92 9o fo 3f 838\nsecurity registered on a national securities exchange and any security not so registered, a\nmanipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal\nRegulations, Section 240.lOb-5, by (a) employing a device, scheme and artifice to defraud;\n(b) making an untrue statement of material fact and omitting to state a material fact necessary in\norder to make the statement made, in light of the circumstances under which it was made, not\nmisleading; and ( c) engaging in an act, practice and course of business which operated and would\noperate as a fraud and deceit upon a person, to wit, KWOK and JE promoted and marketed\nGICLUBS to obtain money from victims through false statements and misrepresentations,\nincluding regarding, among other things, the value of GTV, which scheme was furthered through\nelectronic communications and monetary transfers to and from the Southern District of New York\nand elsewhere.\n(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal\nRegulations, Section 240. lOb-5; and Title 18, United States Code, Section 2.)\nCOUNT EIGHT\n(Wire Fraud - The Himalaya Exchange)\nThe Grand Jury further charges:\n44. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n45. From at least in or about April 2021 up to and including at least in or about March\n2023, in the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, knowingly having devised and intending to devise\na scheme and artifice to defraud, and for obtaining money and property by means of false and\nfraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by\nmeans of wire, radio, and television communication in interstate and foreign commerce, writings,\n29\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 03 0o fo 3f 838\nsigns, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,\nKWOK and JE operated the Himalaya Exchange to fraudulently obtain money from victims\nthrough false statements and misrepresentations, which scheme was furthered through electronic\ncommunications and monetary transfers to and from the Southern District of New York and\nelsewhere.\n(Title 18, United States Code, Sections 1343 and 2.)\nCOUNT NINE\n(International Promotional Money Laundering)\nThe Grand Jury further charges:\n46. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n47. From at least in or about 2018 up to and including at least in or about March 2023,\nin the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING\nJE, a/k/a \"William Je,\" the defendants, did transport, transmit, and transfer, and attempt to\ntransport, transmit, and transfer, a monetary instrument and funds from a place in the United States\nto and through a place outside the United States, and to a place in the United States from and\nthrough a place outside the United States, with the intent to promote the carrying on specified\nunlawful activity, to wit, KWOK and JE directed and made international transfers of funds into,\nout of, and through the United States, with the intent to promote the fraud offenses in Counts Two\nthrough Eight of the Indictment.\n(Title 18, United States Code, Sections 1956(a )(2)(A) and 2.)\n30\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 13 1o fo 3f 838\nCOUNT TEN\n(International Concealment Money Laundering)\nThe Grand Jury further charges:\n48. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n49. From at least in or about 2018 up to and including at least in or about March 2023,\nin the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING\nJE, a/k/a \"William Je,\" the defendants, did transport, transmit, and transfer, and attempt to\ntransport, transmit, and transfer, a monetary instrument and funds from a place in the United States\nto and through a place outside the United States, and to a place in the United States from and\nthrough a place outside the United States, knowing that the monetary instrument and funds\ninvolved in the transportation, transmission, and transfer represented the proceeds of some form\nof unlawful activity, and knowing that such transportation, transmission, and transfer was designed\nin whole and in part to conceal and disguise the nature, location, source, ownership, and control\nof the proceeds of specified unlawful activity, namely, the fraud offenses alleged in Counts Two\nthrough Eight of this Indictment, to wit, KWOK and JE conducted international financial\ntransactions into, and out of, and through the United States involving fraud proceeds, including,\namong other transactions, transactions involving bank accounts held in the names of entities\nnominally owned by other individuals and by entities not overtly associated with the defendants,\nin order to conceal the ownership, control, and/or receipt of the proceeds of the fraud and the illegal\nnature and source of such proceeds.\n(Title 18, United States Code, Sections 1956(a )(2)(B)(i) and 2.)\n31\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 23 2o fo 3f 838\n1/f\nCOUNT ELEVEN\n(Unlawful Monetary Transactions)\nThe Grand Jury further charges:\n50. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n51. On or about June 5, 2020, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles\nKwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE,\na/k/a \"William Je,\" the defendants, within the United States, knowingly engaged and attempted to\nengage in a monetary transaction, as defined in Title 18, United States Code, Section 1957(f)(l),\nin criminally derived property of a value greater than $10,000 that was derived from specified\nunlawful activity, to wit, KWOK and JE made, and directed others to make, a wire transfer of\napproximately $100 million derived from the offenses charged in Counts Two and Three to\nFund-1.\n(Title 18, United States Code, Sections 1957 and 2.)\nCOUNT TWELVE\n(Obstruction of Justice)\nThe Grand Jury further charges:\n52. The allegations contained in paragraphs 1 through 24 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n53. From at least on or about September 20, 2022 through the date of the filing of this\nIndictment, in the Southern District of New York and elsewhere, KIN MING JE, a/k/a \"William\nJe,\" the defendant, corruptly obstructed, influenced, and impeded an official proceeding and\nattempted so to do, to wit, JE attempted to transfer money to the UAE, beyond the jurisdiction of\nthe United States, to impede and interfere with a federal grand jury investigation in the Southern\n32\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 33 3o fo 3f 838\nDistrict ofNew York of the offenses alleged in Counts One through Eleven of this Indictment, and\nproceedings before the United States District Court for the Southern District of New York\nconcerning the seizure and forfeiture of criminally derived proceeds.\n(Title 18, United States Code, Sections 1512(c)(2) and 2.)\nFORFEITURE ALLEGATIONS\n54. As a result of committing the offenses alleged in Counts One through Eight of this\nIndictment, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the\ndefendants, shall forfeit to the United States, pursuant to Title 18, United States Code, Section\n981(a)(l)(C) and Title 28 United States Code, Section 2461(c), any and all property, real and\npersonal, that constitutes or is derived from proceeds traceable to the commission of said offenses,\nincluding but not limited to a sum of money in United States currency representing the amount of\nproceeds traceable to the commission of said offenses and, and the following specific property:\na. $64,826.87 in United States currency formerly on deposit in Account\nNumber 5090037713 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\nb. $75,000,000.00 in United States currency formerly on deposit in Account\nNumber 5090037705 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\nc. $467,343.00 in United States currency formerly on deposit in Account\nNumber 5090037754 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\n33\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 43 4o fo 3f 838\n•\nd. $89,992,861.75 in United States currency formerly on deposit in Account\nNumber 5090042770 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\ne. $1,683,077.40 in United States currency formerly on deposit in Account\nNumber 5090042762 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\nf. $85,899,889.20 in United States currency formerly on deposit in Account\nNumber 5090042853 at Silvergate Bank held in the name of\"Hamilton Opportunity Funds SPC,\"\nseized by the Government on or about September 18, 2022;\ng. $48,230,709.62 in United States currency formerly on deposit in Account\nNumber 5090030288 at Silvergate Bank held in the name of\"Hamilton Investment Management\"\nLtd., seized by the Government on or about September 18, 2022;\nh. $1,800,000.00 in United States currency formerly on deposit in Account\nNumber 5090037739 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\ni. $85,899,889.20 in United States currency formerly on deposit in Account\nNumber 5090042853 at Silvergate Bank held in the name of\"Hamilton Opportunity Funds SPC,\"\nseized by the Government on or about September 18, 2022;\nj. $4,643,744.70 in United States currency formerly on deposit in Account\nNumber 7801000590 at FV Bank held in the name of \"Himalaya International Reserves, Ltd.,\"\nseized by the Government on or about September 20, 2022;\n34\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 53 5o fo 3f 838\n..\n(\nk. $14,599,257.25 in United States currency formerly on deposit in Account\nNumber 7801000254 at FV Bank held in the name of \"Himalaya International Clearing, Ltd.,\"\nseized by the Government on or about September 20, 2022;\nI. $11,538,579.87 in United States currency formerly on deposit in Account\nNumber MBil O1 03-0000 at Mercantile Bank International held in the name of \"G Club\nInternational Ltd.,\" seized by the Government on or about October 16, 2022;\nm. $9,451,170.54 in United States currency formerly on deposit in Account\nNumber MBI10133-0000 at Mercantile Bank International held in the name of \"Himalaya\nInternational Clearing Ltd.,\" seized by the Government on or about October 16, 2022;\nn. $2,823,642.39 in United States currency formerly on deposit in Account\nNumber MBI10137-0000 at Mercantile Bank International held in the name of\"Hamilton Capital\nHolding Ltd.,\" seized by the Government on or about October 16, 2022;\no. $249,000,115.46 in United States currency formerly on deposit in Account\nNumber MBI10138-0000 at Mercantile Bank International held in the name of \"Himalaya\nInternational Reserves Ltd.,\" seized by the Government on or about October 16, 2022;\np. $283,965.11 in United States currency formerly on deposit in Account\nNumber MBI10139-0000 at Mercantile Bank International held in the name of \"Himalaya\nInternational Financial Group Ltd.,\" seized by the Government on or about October 16, 2022;\nq. $1,085,623.67 in United States currency formerly on deposit in Account\nNumber MBil O1 71-0000 at Mercantile Bank International held in the name of \"Hamilton\nInvestment Management Ltd.,\" seized by the Government on or about October 16, 2022;\n35\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 63 6o fo 3f 838\n...\n◄\nr. $43,782.71 in United States currency formerly on deposit in Account\nNumber MBil0l 72-0000 at Mercantile Bank International held in the name of \"G Fashion\nInternational Limited,\" seized by the Government on or about October 16, 2022;\ns. $161,809.47 in United States currency formerly on deposit in Account\nNumber MBil 0 183-0000 at Mercantile Bank International held in the name of \"Himalaya\nCurrency Clearing Pty Ltd.,\" seized by the Government on or about October 16, 2022;\nt. $2,745,377.75 in United States currency formerly on deposit in Account\nNumber 9878904409 at Manufacturers & Traders Trust Co. held in the name of \"GETTR USA,\nInc.,\" seized by the Government on or about September 18, 2022;\nu. $9,899,659.19 in United States currency formerly on deposit in Account\nNumber 157525208185 at US Bank held in the name of \"G Fashion,\" seized by the Government\non or about September 18, 2022;\nv. All that lot or parcel of land, together with its buildings, appurtenances,\nimprovements, fixtures, attachments, and easements, located at 675 Ramapo Valley Road,\nMahwah, New Jersey 07430, Parcel No.3300021-03-00001-02 and described as Lot Number: 1.02\nBlock: 21.03 District: 33 City, Municipality, Township: MAHWAH TWP\nw. A Bugatti Chiron Super Sport, bearing Vehicle Identification Number\nVF9SW3V3XNM795047;\nx. A Lamborghini Aventador SVJ Roads, bearing Vehicle Identification\nNumber ZHWUN6ZD2MLA10393;\ny. A Rolls Royce Phantom EWB, bearing Vehicle Identification Number\nSCAT T8C08MU206445;\n36\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 73 7o fo 3f 838\nJ\nz. A 46m 2014 Feadship superyacht \"Lady May\" (ex Como), bearing IMO\nNumber 112359, MMSI Number 319059500, and Callsign ZGDQ9;\naa. A Besendorfer 185VC Porsche #49539 piano with custom bench, purchased\nfor approximately $140,938.69;\nbb. A Railis Design Iceland Contemporary Poseidon Bed with Nightstands,\nEbony Veneer, Brass, Velvet, purchased for approximately $31,413.71;\ncc. A Hastens 2000T md mattress, purchased for approximately $36,590.00;\ndd. A Hastens 2000T sf mattress, purchased for approximately $36,210.00;\nee. A Wembe watch storage box, purchased for approximately $59,392.91;\nff. A Samsung Q900 Series QN98Q900RBF 98\" QLED Smart TV - 8K,\npurchased for approximately $62,787.54;\ngg. A Louis XV Style French Ormolu-Mounted Mahogany Commode by\nJoseph Emmanuel Zweiner;\nhh. A \"K'ang Hsi\" extension table in etched and patinated pewter and bronze\nwith hand-painted enamel colors by Philip & Kelvin LaV erne, purchased for approximately\n$180,000.00; and\nii. A \"Punto '83\" table in stainless steel with mesh tabletop with adjustable\nheight and adjustable petals by Gabriella Crespi, Italy 1982, purchased for approximately\n$180,000.00.\n(a) through (ii), collectively, the \"Specific Property.\"\n55. As a result of committing the money laundering offenses alleged in Counts One,\nNine, Ten and Eleven of this Indictment, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles\nKwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE,\n37\n\nCaCsaes e1 :12:32-3c-rc-0r-00101181-8A-TA T D oDcoucmumenetn 1t 02- 2 F iFleilde d0 30/30/62/92/32 3 P aPgaeg e3 83 8o fo 3f 838\na/k/a \"William Je,\" the defendants, shall forfeit to the United States, pursuant to Title 18, United\nStates Code, Section 982(a)(l), any and all property, real and personal, involved in said offense,\nor any property traceable to such property, including but not limited to a sum of money in United\nStates currency representing the amount of property involved in said offense and the Specific\nProperty.\nSubstitute Assets Provision\n56. If any of the above-described forfeitable property, as a result of any act or omission\nof the defendants:\na. cannot be located upon the exercise of due diligence;\nb. has been transferred or sold to, or deposited with, a third person;\nc. has been placed beyond the jurisdiction of the Court;\nd. has been substantially diminished in value; or\ne. has been commingled with other property which cannot be subdivided\nwithout difficulty;\nit is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and\nTitle 28, United States Code, Section 2461 ( c) , to seek forfeiture of any other property of the\ndefendants up to the value of the above forfeitable property.\n(Title 18, United States Code, Sections 981 and 982;\nTitle 21, United States Code, Section 853; and\nTitle 28, United States Code, Section 2461.)\n~~\n~~\nFORE N DAMIAN WILLIAMS\n3/\ni.R(c2vEJ3 United States Attorney\n~ -\\.t~ v N:kc s '-\"' \\\n>\" ,t c. \\-~ t '5\ns~ A- USM 'T G--ore/\\-S ft,\n/I\np-,r-\ne~ ..\\ v.1 '\" r re;..,;'\\,..\\- 3 8 fVL (9...","body_zh":null,"key_entities":[],"ecf_references":[],"word_count":11472,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-06 17:58:06"}