{"id":"court_sdny_716_3","court":"SDNY","case_no":"","doc_number":716,"sub_number":null,"doc_type":"DOC","filed_date":"2025-07-28","title":"SDNY ECF 716","summary_zh":null,"summary_en":null,"body_en":"Exhibit C\n\n22 MAG 7581\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\nUNITED STATES OF AMERICA\nTO BE FILED UNDER SEAL\n-v.-\nAffidavit in Support of Seizure\nAll monies and funds contained in US Bank Warrant\naccount 157525208185, held by G Fashion, and\nall funds traceable thereto, including accrued Pursuant to 18 U.S.C. §§ 981 and 984\ninterest (the “Target Account”).\nDefendant-in-rem.\nSOUTHERN DISTRICT OF NEW YORK) ss.:\nAnthony Alecci, Special Agent, Federal Bureau of Investigation, being duly sworn,\ndeposes and says:\nI. Introduction\n1. I am a Special Agent with the Federal Bureau of Investigation (“FBI” or\n“Investigating Agency”). I have been a Special Agent with the FBI since in or about August 2020.\nSince in or about September 2021, I have been assigned to the FBI’s Complex Financial Crimes\nsquad. During my time with the FBI, I have participated in investigations of securities and wire\nfraud schemes, bank fraud, and money laundering, and have, among other things, conducted or\nparticipated in debriefings of witnesses, reviews of financial records, and the execution of search\nwarrants. In particular, I have participated in the execution of search warrants involving physical\npremises, electronic devices, and other electronic evidence.\n2. This affidavit is submitted in support of the United States of America’s Application\nfor the issuance of a seizure warrant, pursuant to 18 U.S.C. §§ 981 and 984, all monies and funds\ncontained in US Bank account 157525208185, held by G Fashion, and all funds traceable thereto,\nincluding accrued interest (the “Target Account”).\n\n3. The Target Account constitutes the proceeds of violations of 18 U.S.C. §§ 1343\n(wire fraud); 1344 (bank fraud); and 1956 (money laundering and conspiracy to commit money\nlaundering) (together, the “Target Offenses”), as described below.\n4. This affidavit is based on, among other sources of information: (i) my personal\nknowledge; (ii) information provided by personnel at the U.S. Securities & Exchange Commission\n(“SEC”) participating in a parallel investigation; (iii) my review of publicly available promotional\nmaterials relating to, among other ventures, “G Club” and the “Himalaya Exchange;” (iv) my\nreview of the publicly available websites for GTV Media Group, Inc. (“GTV”), the Himalaya\nExchange, and “G Club,” and materials available on those websites; (v) open-source research that\nI have conducted on the Internet; (vi) my review of digital videos posted on www.gnews.org\n(“GNews”) by GTV Media Group, Inc. and its employees and agents; (vii) my participation in\nvarious witness interviews; (viii) my review of electronic evidence obtained pursuant to\nsubpoenas, orders issued pursuant to 18 U.S.C. § 2703(d) for non-content information, and\njudicially authorized search warrants; (ix) the review and analysis of various bank account records,\nincluding financial records obtained from financial institutions pursuant to subpoenas and other\nrequests, conducted by myself and financial analysts at the FBI and SEC; (xi) my conversations\nwith other law enforcement officers; and (x) my training and experience concerning the\ncommission of financial crimes. Because this affidavit is being submitted for the limited purpose\nof establishing probable cause, it does not include all the facts that I have learned during the course\nof my investigation. Where dates, figures, and calculations are set forth herein, they are\napproximate. Where the contents of documents and the actions, statements, and conversations of\nothers are reported herein, they are reported in substance and in part, except where otherwise\nindicated.\n5. As set forth below, there is probable cause to believe that the Target Account is\n2\n\nsubject to seizure and forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A), (C) & (D) and 18 U.S.C.\n§981(b) as property involved in violations of 18 U.S.C. § 1956(a)(1)(B)(i) and/or the proceeds of\nviolations of 18 U.S.C. §§ 1343 and 1344, or property traceable thereto. In summary, the evidence\nreveals a series of fraudulent investment schemes (the “Investment Schemes”) that pertain to\nseveral interrelated companies and their affiliated entities, including GTV Media Group Inc., G\nFashion (“G Fashion”), the Himalaya Farm Alliance (the “Farms”), Himalaya International\nClearing Ltd. (“Himalaya International Clearing”), G Club Operations LLC (“G Club”), Hamilton\nInvestment Management Ltd. (“Hamilton”), ACA Capital Group Ltd. (“ACA Capital”), and Crane\nAdvisory Group LLC (“Crane”). As set forth in more detail below, the leaders of the fraudulent\ninvestment schemes are Miles Guo, a/k/a “Guo Wengui,” a/k/a “Miles Kwok” (“GUO”) and\nWilliam Je, a/k/a Je Kin Ming (“JE”).\n6. Analysts at the FBI and SEC and I have traced the flow of certain fraud proceeds\nfrom victims of the Investment Schemes to the Target Account.\nII. Statutory Basis for Forfeiture\n7. The statutory provisions pursuant to which the Target Account is subject to civil\nseizure and forfeiture are as follows:\nMoney Laundering Offenses\n8. Title 18, United States Code, Section 981(a)(1)(A), subjects to civil forfeiture:\nAny property, real or personal, involved in a transaction or attempted transaction in\nviolation of section 1956, 1957 or 1960 of this title, or any property traceable to such\nproperty.\n9. 18 U.S.C. § 1956(a)(1)(B)(i) provides that any person who:\nknowing that the property involved in a financial transaction\ninvolves the proceeds of some form of unlawful activity, conducts\nor attempts to conduct such a financial transaction which in fact\ninvolves the proceeds of specified unlawful activity –\n3\n\n(B) knowing that the transaction is designed in whole or in\npart—\n(i) to conceal or disguise the nature, the location, the\nsource, the ownership, or the control of the proceeds\nof specified unlawful activity [shall be guilty of a\ncrime.]\n10. 18 U.S.C. § 1956(a)(2)(B)(i) provides that any person who:\ntransports, transmits, or transfers, or attempts to transport, transmit,\nor transfer a monetary instrument or funds from a place in the\nUnited States to or through a place outside the United States or to a\nplace in the United States from or through a place outside the\nUnited States—\n(B) knowing that the monetary instrument or funds involved in\nthe transportation, transmission, or transfer represent\nthe proceeds of some form of unlawful activity and knowing that\nsuch transportation, transmission, or transfer is designed in whole or\nin part—\n(i) to conceal or disguise the nature, the location, the source,\nthe ownership, or the control of the proceeds of specified\nunlawful activity [shall be guilty of a crime.]\n11. 18 U.S.C. § 1956(h) further provides that “[a]ny person who conspires to commit\nany offense defined in [Section 1956] shall be subject to the same penalties as those prescribed for\nthe offense the commission of which was the object of the conspiracy.”\nBank and Wire Fraud Offenses\n12. For purposes of Section 1956, “specified unlawful activity,” defined in 18 U.S.C.\n§ 1956(c)(7), includes, among other things, violations of 18 U.S.C. §§ 1343 and 1344. See 18\nU.S.C. §§ 1956(c)(7) and 1961(1).\n13. Title 18, United States Code, Section 981(a)(1)(C), subjects to civil forfeiture any\nproperty, real or personal, which constitutes or is derived from proceeds traceable to a violation\nof . . . any offense constituting ‘specified unlawful activity’ (as defined in section 1956(c)(7) of\nthis title), or a conspiracy to commit such offense.”\n4\n\nSeizure Warrants\n14. The Court is empowered by 18 U.S.C. § 981(b) to issue a seizure warrant for any\nproperty subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A) & (C). Section 981(b)(2)\nprovides that such a seizure may be made “pursuant to a warrant obtained in the same manner as\nprovided for a search warrant under the Federal Rules of Criminal Procedure.” In addition, Section\n981(b)(3) provides that, notwithstanding the provisions of Federal Rule of Criminal Procedure\n41(a), a seizure warrant may be issued pursuant to Section 981(b) by a judicial officer in any\ndistrict in which a forfeiture action against the property may be filed under Title 28, United States\nCode, Section 1355(b). Under Section 1355(b)(1)(A), a forfeiture action or proceeding may be\nbrought in the district in which any of the acts or omissions giving rise to the forfeiture occurred.\nAs set forth below, the offenses underlying the requested seizure warrant included acts or\nomissions occurring in the Southern District of New York.\n15. With respect to fungible property, including cash and funds deposited in a financial\ninstitution, 18 U.S.C. § 984 provides, in relevant part, that:\n(a)(1) In any forfeiture action in rem in which the subject property is cash, monetary\ninstruments in bearer form, funds deposited in an account in a financial institution . . . , or\nprecious metals:\n(A) it shall not be necessary for the Government to identify the specific property\ninvolved in the offense that is the basis for the forfeiture; and\n(B) it shall not be a defense that the property involved in such an offense has\nbeen removed and replaced by identical property.\n(2) Except as provided in subsection (b), any identical property found in the same place\nor account as the property involved in the offense that is the basis for the forfeiture shall\nbe subject to forfeiture under this section.\n(b) No action pursuant to this section to forfeit property not traceable directly to the\noffense that is the basis for the forfeiture may be commenced more than 1 year from the\ndate of the offense.\n5\n\nIII. Probable Cause\nA. Probable Cause Regarding Commission of the Subject Offenses\nOverview of the Fraudulent Investment Schemes\n16. Since in or around May 2020, the United States Attorney’s Office for the Southern\nDistrict of New York (“SDNY”) and the FBI, among other law enforcement agencies, have been\ninvestigating a series of interrelated fraudulent investment schemes that pertain to several\ncompanies that are owned or operated by, or otherwise affiliated with, GUO, JE, and their\nassociates (collectively, the “Investment Schemes”). To date, the investigation (“Investigation”)\nhas revealed that the Investment Schemes involve the solicitation and subsequent investment\nand/or misappropriation of hundreds of millions of dollars. GUO and JE are leaders of the\nInvestment Schemes.\n17. The Investment Schemes are conducted through various, interrelated offerings, all\nof which exhibit features that are consistent with fraud. For example, investors are promised\nunrealistic, outsized returns on their investments; investors are induced to invest on the basis of\nnumerous misrepresentations; a large portion of the investment money is misappropriated; and\nwith respect to the sale of digital asset securities, those currencies have never been tradable on a\npublic exchange, despite representations that they would be.\n18. While certain of the interrelated Investment Schemes are ongoing, others are\nhistorical. Specifically:\na. The GTV stock offering and the G Coin offering described below\n(collectively, the “Unregistered Stock Offerings”) operated between in or about April 2020 and in\nor about July 2020. As a result of the Unregistered Stock Offerings, whose proceeds were\ncommingled, companies affiliated with GUO, JE, and others collectively raised at least\n6\n\napproximately $487 million from more than 5,000 investors, including individuals in the United\nStates.\nb. Starting at least in or about July 2020, the leaders of the scheme began to\npitch investors on a new set of investment opportunities, marketed as an opportunity to convert\ntheir existing investments in GTV into a “loan” to GTV (the “Convertible Loan Offering”). The\nConvertible Loan Offering was carried out by the Guo-backed “Himalaya Farm Alliance,” which\nconsists of informal groups, or “Farms,” of Chinese expatriates located in various cities around the\nworld. Between in or about August 2020 and March 2021, the U.S.-based Farms raised\napproximately $148 million from the Convertible Loan Offering.\nc. GUO, JE, and others continue to conduct the Investment Schemes,\nincluding relating to G Club (which has been operating since in or about October 2020) and the\nHimalaya Exchange (which has been operating since in or about April 2021).\nBackground on GUO and JE\n19. Based on my participation in this investigation, training, experience, review of law\nenforcement reports, review of documents, records, videos that were posted on social media\nplatforms, and public source research that I have conducted on the Internet, as well as my\nconversations with others, I have learned the following, among other things:\na. GUO is a purported billionaire and a Chinese national who allegedly fled\nChina for the United States in 2014, after learning that an associate had been arrested on corruption\ncharges.\nb. GUO is involved with various entities relevant to the Investment Schemes,\nas described in greater detail below, including GTV, G Music LLC (“G Music”), G Club, G\nFashion (“G Fashion”), and GETTR USA, Inc. (“Gettr”). GUO does not hold formal titles or\npositions at these entities.\n7\n\nc. In or about 2018, GUO founded organizations named the Rule of Law\nFoundation (“ROLF”) and Rule of Law Society (“ROLS”). Based on my review of publicly\navailable information, I have learned that the Rule of Law projects were underway by December\n2018.1 ROLF and ROLS are purportedly organizations dedicated to exposing and combatting\ncorruption in China by the Chinese Communist Party (“CCP”). At times, the board members for\nROLF and/or ROLS have included Stephen K. Bannon (“Bannon”) and Kyle Bass (“Bass”). GUO\ndoes not hold a formal position at ROLF or ROLS; however, on the ROLS website, GUO is\ndescribed as “the founder, a promoter and a spokesperson” and a sponsor.\nd. JE, a close associate of GUO, has been described as a financier and\nentrepreneur. JE is involved with various other entities relevant to the Investment Schemes, as\ndescribed in greater detail below. Specifically:\ni. JE is the CEO of Hamilton Investment Management Ltd.\n(“Hamilton”), a purported global fund management company.2 Hamilton is headquartered in the\nBritish Virgin Islands and was incorporated on or about February 5, 2018. JE was formally\nappointed Director of Hamilton on or about March 20, 2019.\nii. JE is the Director of ACA Capital Group Ltd. (“ACA Capital”), a\npurported Hong Kong-based investment firm3 that was incorporated in the United Kingdom on or\nabout July 10, 2020.\niii. JE is listed as the founder and Chairman of Himalaya Exchange, a\npurported cryptocurrency “ecosystem.” JE is the 100% beneficial owner of various entities that\n1 See http\n(describing Guo and Bannon’s involvement in the “Rule of Law Fund”).\n2 See http\n3 See http\n8\n\noperate Himalaya Exchange, including Himalaya International Clearing Ltd. (“Himalaya\nClearing”), Major Lead International Ltd., Himalaya International Financial Group Ltd.\n(“Himalaya Financial”), and Himalaya International Reserves Ltd. (“Himalaya Reserves”).\nGTV Stock Offering\n20. Between approximately April 20, 2020 and June 2, 2020, GTV, its parent company\nSaraca Media Group, Inc. (“Saraca”), and Voice of Guo Media, Inc. (“VOG”; collectively, the\n“Companies”) solicited thousands of individuals to invest in an offering of GTV common stock\n(the “GTV Stock Offering”). During that time period, more than approximately 5,000 investors\n(including many in the United States) collectively paid approximately $452 million for purported\nGTV common stock.\n21. Based on my review of the GTV Stock Offering’s information memorandum dated\nApril 20, 2020 (the “Memorandum”), interviews of witnesses, and review of public source\ninformation, as well as documents and records obtained during the course of the investigation, I\nhave learned the following, among other things:\na. GTV was founded on or about April 17, 2020, as a Delaware corporation\nand a wholly owned subsidiary of Saraca. GTV’s principal place of business was located in the\nSouthern District of New York, in a townhouse located at 162 E. 64th St., New York, NY, 10065\n(the “Townhouse”).\nb. According to the Memorandum, GUO was the “sponsor” of both Saraca and\nGTV, as well as the “adviser[sic]” and “key host” of GTV. The Memorandum also stated that\nGUO was a billionaire, successful businessman, and dissident in China. According to various\nwitnesses, as well as social media content, GUO consistently presented himself as the founder and\nface of GTV.\n9\n\nc. The Memorandum and a separate letter to prospective investors outlining\n“Investment Procedures Guidelines” listed GUO’s phone number as the contact number for\ninquiries from potential investors.\nd. At the time of the GTV Stock Offering, the Companies had recently\nlaunched a news-focused social media platform called GTV, including the website www.gtv.org.\nThe Memorandum claimed GTV would be “the first ever platform which w[ould] 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” and that GTV\nwould be “the only uncensored and independent bridge between China and the Western world.”\nThe Memorandum also claimed that GTV would “be a bridge between China and the Western\nworld . . . allowing for free and open communication, business transactions and trading,\nuncensored by the Chinese government.” The Memorandum boasted that GTV’s platform would\nbe so powerful as to “expos[e] corruption, obstruction, illegality, brutality, harassment, and\ninhumanity in China.” The Memorandum also indicated that GTV would compete with companies\nsuch as Zoom, WeChat, TikTok, YouTube, Cisco, Citrix, Alibaba, Amazon, and eBay.\ne. The Memorandum listed Yvette Y. Wang, Max Krasner, and Daniel\nPodhaskie as GTV’s Executive Directors.\nf. The Memorandum highlighted the credentials of GTV’s Non-executive\nDirectors, including, among others, Bannon, Bass, and Darren Blanton (“Blanton”). As described\nabove, Bannon and Bass were also board members of the ROLF and/or ROLS.\ng. The Memorandum stated that investor funds would be used for the\nfollowing, among other purposes: acquisition of companies; upgrading GTV technology and\nsecurity; and marketing. The Memorandum did not contemplate that investor funds would be used\n10\n\nto invest in hedge funds or any similar type of financial investment, or that investor funds would\nbe given to other companies, such as Saraca.\nh. Based on my conversations with a source of information (the “SOI4”)\ninvolved with the ROLF, the Companies, the GTV Stock Offering, and the Phoenix Farm, as well\nas my review of the metadata of the Memorandum, I have learned that JE was a primary author of\nthe Memorandum.\nG Coin Offering\n22. During the same period of April 2020 through June 2020, GTV and Saraca also\nsolicited GTV Investors to invest in a companion digital asset security that was referred to as either\nG-Coins or G-Dollars (the “G Coin Offering”).\n23. Based on my participation in this investigation, training, experience, review of law\nenforcement reports, review of bank records and videos that were posted on social media\nplatforms, as well as my review of reports of interviews with GTV Investors and conversations\nwith others, including law enforcement, I have learned the following, among other things, about\nthe G Coin Offering:\na. From approximately in or about April 2020, through at least in or about June\n2020, I have learned that the Companies, as well as representatives for the Companies, such as\nGUO, marketed the sale of G-Coins and G-Dollars to the public through online videos on\nYouTube, Twitter, and other video-sharing and social media platforms.\nb. The Companies’ online promotions set forth that G-Coins (which the\nCompanies indicated would eventually be merged into G-Dollars, forming a single digital asset),\n4 The SOI is providing information to law enforcement in hopes of entering into a cooperation\nagreement and receiving leniency at sentencing. The SOI has provided reliable information that\nhas been corroborated by, among other things, electronic evidence, videos, cellphone records, and\nsubpoena and search warrant returns.\n11\n\nand G-Dollars would be usable to purchase goods or services or exchange for gold or fiat currency\non an online platform. As part of its solicitation of G-Coin and G-Dollar investors, the Companies\ndid not provide investors with financial information about the plan to develop any digital asset or\nplatform, or any written offering materials, including, for example, a whitepaper or private\nplacement memorandum.\nc. The Companies collected at least approximately $31 million from the G-\nCoin and G-Dollar Investors, pooling the proceeds in bank accounts associated with the\nCompanies and commingling them with proceeds from the GTV Stock Offering. As part of the G\nCoin Offering, many investors received a purported 20% discount on the $.01 purchase price for\nG-Coins and G-Dollars. Investors participated in the G Coin Offering by transferring funds\ndirectly to the Companies’ U.S. bank accounts, by making payments to the Companies’ accounts\non online payment platforms, by making purchases via the Apple App Store, or by writing checks.\n24. Based on my participation in this Investigation, training, experience, and review of\ntranslations of statements that were made by GUO regarding the G Coin Offering, as well as my\nconversations with others, I have learned that GUO made numerous false statements in order to\nsolicit investments for the G Coin Offering. Examples of some those statements are described\nbelow, in substance and in part:\na. In a statement contained within a video by GUO on or about May 9, 2020,\nGuo stated that G-Coins could be exchanged into U.S. dollars or physical gold.\nb. In another statement contained within a video on or about May 16, 2020,\nGUO stated that the G-Coin and G-Dollar currencies could be exchanged with gold.\n25. Based on my participation in this investigation, I believe that the above-described\nstatements regarding G-Coins and G-Dollar are false. In particular, during the course of the\n12\n\ninvestigation, I have not found any evidence that there is or has ever been an exchange where G-\nCoins or G-Dollars could be exchanged for U.S. dollars or gold.\n26. Based on my participation in this Investigation, training, experience, review of law\nenforcement reports, review of bank records, and review of videos that were posted on social media\nplatforms, as well as my review of reports of interviewed individuals who invested in GTV (the\n“GTV Investors”) and my conversations with others, including other law enforcement officers, I\nhave learned the following, among other things, about the solicitation of investments for the GTV\nStock Offering and G Coin Offering:\na. GTV disseminated information about the two offerings to the general public\nthrough publicly-available videos on websites affiliated with the Companies, including\nwww.gtv.org and www.gnews.org, as well as on social media platforms such as YouTube and\nTwitter. The first solicitation video, posted on YouTube on April 21, 2020, was entitled, as\ntranslated into English, “GTV Private Placement Subscription Instructions” (the “Launch Video”).\nThe Launch Video described the investment terms for the GTV Stock Offering and provided a\nmobile phone number for potential investors to use for inquiries about the offering. The Launch\nVideo has had over 3,000 views. None of the GTV Stock Offering solicitation videos, including\nthe Launch Video, were password protected or placed any restriction on who could view them or\nany limitations on their ability to be shared. As a result, the general public, including prospective\nU.S. investors, were able to access the online marketing videos about the GTV Stock Offering\nthrough, for example, independent online research, social media, or referrals from other investors.\nb. GUO led the effort to solicit investors for the GTV Stock Offering. GUO,\nwho is a prolific user of social media and has an enormous social media following, used various\nsocial media platforms to attract followers and to solicit investors for the GTV Stock Offering.\nThose social media platforms included WhatsApp and Discord, both of which have end-to-end\n13\n\nencrypted chat services.5 Among other things, the Companies sent the Launch Video via phone\nmessages to hundreds of prospective individual investors with a link to a Google Drive folder that\ncontained additional offering material for the GTV Stock Offering, including the subscription\nagreement and investment instructions. GUO also assured potential investors that they would\nrealize enormous returns, at one point suggesting that they would receive 1,000 times their\ninvestment, see infra ¶ 40(c). In another statement, in or about June 2020, GUO stated in substance\nand in part that GTV stock was worth 30 times what it had been worth before.\nc. Based on my review of a GTV confidentiality agreement, I have learned\nthat in order to participate in the GTV Stock Offering, GTV Investors were required to sign a\nconfidentiality agreement that required them to keep all information concerning GTV confidential,\nincluding the existence of the confidentiality agreement.\nd. The GTV Stock Offering was structured as a private placement offering of\n10% into GTV, with the remaining 90% of GTV to be controlled by Saraca, which was its parent\ncompany. According to due diligence records from an investment fund, Saraca is a wholly-owned\nsubsidiary of Hudson Diamond Holding, Inc. (“Hudson BVI”), a British Virgin Islands company.\nHudson is in turn wholly owned by Qiang Guo (“QIANG GUO”). Based on my review of open-\nsource material, I have learned that QIANG GUO is GUO’S son.\ne. By early June 2020, banks began to suspect that the Companies were\nengaged in potentially unlawful activity and started to close accounts that were linked to Saraca,\nGTV, and GUO. Around that same time period, GTV Investors began to express concerns about\n5 End-to-end encryption is a system of communication where only the communicating users can\nread the messages. End-to-end encryption prevents law enforcement authorities from intercepting\nsuch communications through wiretaps or through search warrants on the service provider, such\nas WhatsApp.\n14\n\nGTV’s use of their money, and the legitimacy of their investments. Some of those investors\nexpressed their concerns directly to GUO and many investors requested that their money be\nreturned. In response, GUO and his associates often attempted to shun and ostracize the investors.\nFor example, GUO suggested that one investor was a spy for the CCP and that other investors\nshould not interact with that investor\nMisappropriation of Unregistered Stock Offering Funds\n27. A significant portion of the investor funds collected through the Unregistered Stock\nOfferings (collectively, “Offering Funds”) were misappropriated through investments.\n28. Based on my participation in this Investigation, training, experience, review of law\nenforcement reports, review of bank records and subpoena returns, as well as my conversations\nwith others, including law enforcement and witnesses, I have learned the following, among other\nthings:\na. GUO, JE, and others arranged for approximately $100 million of the\nOfferings Funds to get invested on behalf of GTV’s parent company, Saraca, in a high-risk hedge\nfund investment managed by a firm named Hayman Capital Management L.P. (“Hayman”).\nAccording to its website, Hayman is an SEC-registered asset management firm that was founded\nby Bass, who was a non-executive director of GTV at the time of the transfer.\nb. In or about May 2020, Bass facilitated GUO’s and JE’s investment in a\nhigh-risk investment fund called the Hayman Hong Kong Opportunities Fund (the “Hayman\nFund”), which was operated by Hayman.\nc. JE coordinated with Hayman regarding the investment. For example, in a\nMay 29, 2020 email from JE to a Hayman representative (“Hayman Rep-1”), JE wrote, in\nsubstance and in part: “We will have one onshore and one offshore vehicle. The onshore one will\ninvest USD100m and the offshore one will invest USD1m. The address of the onshore vehicle is:\n15\n\n162 E64th St., New York, NY 10065 United States.” On or about May 31, 2020, JE wrote, in\nsubstance and in part, “The $1m will come from my personal account and I owned[sic] 100% of\nHamilton Investment Management Ltd.”\ni. The address JE provided for the “onshore” vehicle is the address of\nthe Townhouse. See supra ¶ 21(a).\nii. Based on my participation in this Investigation, review of bank\nrecords and subpoena returns, as well as my conversations with others, including law enforcement\nand witnesses, I have learned that the Townhouse has been listed on corporate documents and/or\nbank account documentation as the business address for at least seven GUO-affiliated entities;\nspecifically: Saraca, GTV, Golden Spring, Hudson Diamond NY, Greenwich Land, ROLF (until\napproximately May 2022), and ROLS (until approximately May 2022).\nd. Three days after the close of the GTV Stock Offering, on or about June 5,\n2020, $100 million of the Offering Funds were transferred from a particular JP Morgan Chase\nbank account to an onshore bank account associated with Hayman for the purpose of investing in\nthe Hayman Fund. The funds were transferred on behalf of Saraca; as noted above, Saraca was\nthe parent company to GTV and was 100% owned by GUO’s son, QIANG QUO.\ne. Three days later, on or about June 8, 2020, $1 million was transferred on\nbehalf of Hamilton,6 JE’s company, from a bank account in the name of JE to an offshore bank\naccount associated with Hayman, also for the purpose of investing in the Hayman Fund.\nf. The transfer of Offering Funds to Hayman was completely inconsistent with\nGTV’s representations to the GTV Investors about how their funds would be used.\n6 In April 2018, JE submitted on behalf of Hamilton an account opening document to a U.K. bank\nthat claimed that he owns 100% of Hamilton and that the company “does not involve itself in\ninvestments.”\n16\n\n29. Based on my participation in this Investigation, training, experience, review of\ndocuments and records, as well as my conversations with others, including law enforcement, I\nhave learned that on or about September 13, 2021, the SEC announced settled charges against\nthe Companies, based on their violations of the registration requirements for the Unregistered\nStock Offerings (i.e., the GTV Stock Offering and the associated digital asset G Coin Offering).\nThe SEC’s settlement required the Companies to pay more than $539 million in disgorgement\nand penalties.\nThe Convertible Loan Offering\n30. After the Unregistered Stock Offerings described above were discovered by banks\nand numerous bank accounts were frozen, leaders of the schemes began to pitch investors on a\nnew set of investment opportunities. One new investment scheme launched in or about July 2020\nwas marketed to prospective investors as an opportunity to convert their existing investments in\nGTV into a “loan” to GTV. The Convertible Loan Offering was carried out by the “Himalaya\nFarm Alliance,” a collective of informal groups—known as “Farms”—of Chinese expatriates\nlocated in various cities around the world, including New York and Phoenix. The Himalaya Farm\nAlliance’s purported purpose was to assist the Chinese pro-democracy movement; the Himalaya\nFarm Alliance existed primarily as private groups on social media platforms such as Discord.\na. The Farms were typically referred to by the names of preexisting companies\nthat they affiliated themselves with for banking purposes. That is, the Farms opened and operated\nbank accounts in the names of various corporate entities.\nb. The Phoenix Farm was affiliated with Maywind Trading LLC\n(“Maywind”), Medical Supply System International LLC (“Medical Supply System”) and Santel\nLLC (“Santel”), while the New York Farm was affiliated with Mountains of Spices LLC\n(“Mountains of Spices”) and Davy & Tony International Limited (“Davy & Tony”).\n17\n\n31. In connection with the Convertible Loan Offering, the Farms provided prospective\ninvestors with a “Loan Agreement” that disclosed that the loan would be made to the individual\nFarm (e.g., “Phoenix Farm (Maywind Trading LLC)”) and that the loaned funds would be used by\nthat specific Farm for “general working capital purposes.” Investors executed the Loan Agreement\nand sent it to their Farm leaders after transferring their funds to the Farm, but were not provided\ncounter-executed copies of the agreement.\n32. Between in or about August 2020 and in or about March 2021, the U.S.-based\nFarms collectively raised approximately $148 million from the Convertible Loan Offering (the\n“Loan Funds”). Investors agreed to provide loans to the Farms for the purpose of acquiring GTV\nshares (once the three-year note had matured). Once the funds were collected by the U.S. Farms,\nthey were transferred to domestic and foreign accounts owned by different legal entities, including\nan Abu Dhabi bank account in the name of ACA Capital (the “UAE ACA Capital Account”),\nwhich is owned and controlled by JE.\nMisappropriation of Convertible Loan Offering Funds\n33. A significant portion of the Loan Funds collected through the Convertible Loan\nOffering were misappropriated, as described below.\n34. Based on my participation in this Investigation, training, experience, review of law\nenforcement reports, review of bank records and subpoena returns, as well as my conversations\nwith others, including law enforcement and witnesses, I have learned the following, among other\nthings:\na. JE was sole signatory of the UAE ACA Capital Account. JE wired\napproximately $33.3 million of the Loan Funds out of the UAE ACA Capital Account to Swiss\nand UK accounts belonging to himself, his wife (Sin Ring Rong), and his company, Hamilton.\nThe wires to his and his wife’s personal accounts—which amounted to more than approximately\n18\n\n$10 million—were described as dividends, salary or director fees. However, JE was not a director\nor employee of GTV, Saraca, or other affiliated entities.\nb. JE arranged for approximately $34 million in transfers from UAE ACA\nCapital Account to U.S. bank accounts in the names of three companies that are each 100% owned\nby GUO’s family members; specifically:\ni. Approximately $5 million to Greenwich Land LLC, which is owned\nby GUO’s wife, Hing Chi Ngok;\nii. Approximately $18 million to Hudson Diamond NY LLC, which is\nowned by Guo’s daughter, Mei Guo; and\niii. Approximately $11 million to Lamp Capital LLC, which is owned\nby Guo’s son, QIANG GUO.\nc. The $34 million was commingled with other investor funds, including GTV\nOffering Funds. Based on my review of bank account records, I have learned that much of this\nGTV Investor money was used to fund lavish lifestyle expenses (e.g., approximately $2.3 million\nin expenses relating to GUO’s yacht, and approximately $600,000 for the purchase of luxury\nautomobiles).\nd. JE also arranged for large transfers from UAE ACA Capital Account to other\ncompanies with ties to GUO; specifically:\ni. Approximately $19 million to Lexington Property and Staffing, Inc.\n(“Lexington Property”), which is owned by former GTV Treasurer, Anthony DiBattista\n(“DiBattista”). The registered address of Lexington Property is 750 Lexington Avenue, New\nYork, NY;\n19\n\nii. Approximately $32 million to Savio Law LLC (as escrow agent),\npursuant to a purported loan agreement between ACA Capital and Saraca (which is owned by\nGUO’s son, QIANG GUO); and\niii. Approximately $1 million to Bannon Film Industries, Inc., a\ncompany owned by Steve Bannon. As described above, Bannon was listed in the Memorandum\nas a non-executive GTV Director and was a Director of the ROLF / ROLS.\nThe G Club Operations LLC Scheme\n35. Some of the Farms recruited investors to invest in GTV through the purchase of “G\nClub” memberships. As described in greater detail below, law enforcement believes G Club is an\nongoing fraudulent scheme operated by GUO, JE, and others.\n36. Based on my participation in this Investigation, training, experience, review of the\nwebsites, subpoena returns, records and documents, including operating agreements and articles\nof incorporation, open-source research I have conducted on the Internet, and my conversations\nwith others, including law enforcement, I have learned the following, among other things:\na. In or about October 2020, G Club Operations LLC (“G Club”) was\nregistered in Puerto Rico. According to the Operating Agreement, the purpose of G Club is to\n“provide[] Membership Concierge services with exclusive offers and discounts for luxury hotels\nand retailers for High Net Worth individuals from the Asian market.”\nb. An image from the G Club website (“G Club Website”), viewable at\nhttp is shown below:\n20\n\n37. G Club purportedly offers five membership tiers: Tier 5 Membership ($50,000\nannually); Tier 4 Membership ($40,000 annually); Tier 3 Membership ($30,000 annually); Tier 2\nMembership ($20,000 annually); and Tier 1 Membership ($10,000 annually). According to the G\nClub Membership Agreement, “A Member may subsequently elect a higher tier of membership,”\nbut “may not subsequently elect a lower tier of Membership.” The annual fee for the desired\nmembership tier must be paid in full with the submission of the G Club membership application,\nand G Club reserves the right to reject any membership application within 30 days at its sole and\nabsolute discretion. The Membership Agreement further states: “If an Application is rejected and\nmembership denied, G Clubs shall return the Membership Fee within ten (10) calendar days of\nsuch rejection . . . in the form of the original payment of the Membership Fee or, at the option of\nG Clubs, by check.”\n38. One photograph posted to the G Club Website depicted GUO living a lavish\nlifestyle; specifically, he is shown standing on top of what appears to be a large yacht smoking a\ncigar. The G Club Website also states that:\nG Clubs memberships provide its members with access to a concierge customer\nservice with Mandarin and English access and support. G Clubs members will have\n21\n\nthe opportunity to attend the annual G Summit meeting which may occur in person\nor virtually. G Clubs members will also get exclusive early access to the latest\nfashion collections and special member pricing on purchases made on the G\nFashion website.\n39. In a video summary posted on GNews on or about July 8, 2021, Guo claimed that\nG Club had approximately 25,000 members, and predicted that G Club would grow to at least 100\nmillion users, attracting $16 trillion of investment.\n40. Despite the representations on the G Club Website about purported membership\nbenefits, law enforcement believes that G Club is being used, at least in part, to perpetuate the\nfraud schemes, including by soliciting and receiving investments while evading regulatory\nrequirements. Specifically, based on my review of an interview report of an August 2, 2021\ninterview (the “August 2, 2021 Interview”) conducted by others of a GTV investor (“Investor-1”),\nI have learned that Investor-1 stated the following, in substance and in part, during that interview:\na. Investor-1 invested $200,000 USD in GTV in or around May 2020.\nInvestor-1’s money came from Investor-1’s savings.\nb. Investor-1 came to believe that GTV was a scam because Investor-1 did not\nreceive any GTV shares, and when Investor-1 asked for a refund, no one responded to Investor-1.\nc. Investor-1 invested in GTV because: 1) there were a lot of American\npoliticians supporting Guo; (2) Guo said it was original stock and there would be at least 1,000x\ngrowth; and (3) Investor-1 thought Investor-1 would make money on the GTV stock because Guo\nsaid this in videos. Investor-1 did not think Investor-1 would lose money because Guo promised\nthe GTV investment would make money.\nd. Investor-1 thought that GTV would use the money to build a website like\nYouTube, Facebook and Twitter, but did not know for certain what it would be used for.\n22\n\ne. Investor-1 subsequently invested in the Convertible Loan Program through\nthe “Canada Farm” in or around August 2020. Specifically, Investor-1 sent approximately $71,019\nto “Canada Himalayan Club Medica Inc.” as a loan. Investor-1 believed that the loan was for 3-5\nyears, with 3% interest and that at the end of that period Investor-1 would receive the money or\nGTV stock. Investor-1 never received an executed copy of the investment contract. The money\nInvestor-1 sent was frozen by the Canadian SEC.\nf. Investor-1 attempted to invest in GTV again in or around March 2021\nthrough G Club. Specifically, Investor-1 was instructed to send Investor-1’s investment funds to\n“Crane Advisory Group,” who in turn would send the money to G Club. Investor-1 sent\napproximately $100,015 to Crane Advisory Group for the purchase of GTV shares at the price of\n$1 per ten shares.\ng. In or around July 2021, Investor-1 attempted to initiate a refund by\ncontacting G Club online customer service department. In response to Investor-1’s refund request,\nG Club, through “notices@gclubs.com,” sent the following email:\nYou recently made a payment with respect to your G|CLUBS membership through\nCrane. Your wire payment transfer exceeded the amount of a single membership\nand you have not applied for multiple memberships. We received $100,015.00 via\nwire. You had applied for one Tier 5 membership and filled out the KYC package\nindicating the total amount was for multi membership of G|CLUBS (see attached).\nTo credit the total amount to you, you must apply for additional memberships.\nPlease fill and sign the attached, advising how many memberships you wish to\npurchase and their tier.\nIf sending the excess funds was an error and you wish an immediate return of\n$50,015, please immediately advise. We sincerely apologize for any inconvenience\ncaused.\nh. In response, Investor-1 informed G Club that Investor-1 had sent the $100,015.00\nin funds not to purchase a G Club membership, but rather to invest in GTV. Investor-1 requested\nthat all of Investor-1’s funds be returned. In a subsequent email, Investor-1 also noted that it would\n23\n\nnot have made sense for Investor-1 to send a sum of $100,015.00, given that the most expensive\nG Club membership cost $50,000. Investor-1 also explained in another email that, in a phone\nconversation with a representative of G Club, the representative had made it clear that Investor-\n1’s funds were going to be used for an investment in GTV, not for the purchase of a G Club\nmembership.\ni. Investor-1 had not received any of Investor-1’s $100,015 investment back as of the\ndate of the interview.\n41. Based on my participation in this Investigation, my review of law enforcement\nreports, court filings, review of bank records, subpoena returns, and search warrant returns, my\ntraining and experience, as well as my conversations with others, including law enforcement and\nwitnesses, I have learned the following, among other things:\na. Based on my review of an informal translation and transcription of a voice\nmessage that GUO sent to the SOI and others via WhatsApp in or about 2020, which was provided\npursuant to a subpoena, I have learned that GUO directed the Phoenix Farm to send its “40 million\nloan money” (i.e., Convertible Loan Offering funds) “in different wires, on different days, to\nGFashion in Los Angeles, and then use a loan agreement to legalize the wires. Leanne [Li] and\nTiantian [Hao] have already coordinated with banks in California. You three together please figure\nout how the money goes into these accounts and solve this issue, OK?”\nb. On or about July 31, 2020, the following entities were registered for\nincorporation in the State of California: “G Club,” “G Club One,” “G Club Two,” “G Club Three,”\nand “G Fashion” (the “California G Entities”). The registration filings for the California G Entities\nall had the same registered address (800 N Harper Ave, Los Angeles, California 90046) and\nofficers (Leanne Li (“LI”) as CEO and Secretary, and Tian Hao (“HAO”) as CFO and Director).\nThe type of business listed for each of the California G Entities was “Fashion.” Based on my\n24\n\nopen-source research, I have learned that the listed address appears to be a residential address,\nwhich, based on my training and experience, is an indicia of money laundering.\n42. Based on my participation in this Investigation, training, experience, my review of\ndocuments, records, and email search warrant returns, as well as my conversations with others,\nincluding witnesses, I have learned the following, among other things:\na. An individual named Alex Hadjicharalambous (“Hadjicharalambous”), whose title\nwas the Financial Controller for G Club, was the authorized signer listed on multiple bank accounts\nin the name of G Club. On July 13, 2021, Hadjicharalambous received an email at his G Club\nemail account (alexh@gclubs.com) from a G Fashion IT Manager entitled “HCHKTech email”\nthat read, in substance and in part: “Hello Alex, As you know we now work for HCHK\nTechnologies. Use the credentials in this email and follow the steps below to log into your new\nemail account.”\nb. Based on my review of open-source material on the Internet and subpoena returns,\nI have learned the following, among other things:\ni. On or about April 29, 2021, HCHK Technologies, Inc. (“HCHK\nTechnologies”) was incorporated in the State of Delaware. At the time of incorporation, Anthony\nDiBattista was director of HCHK Technologies. Between on or about May 27, 2021 and\nNovember 10, 2021, DiBattista was Treasurer of HCHK Technologies. On or about December\n13, 2021, DiBattista resigned as President, CEO, and Director of HCHK Technologies.\nc. On or about August 18, 2021, HCHK Property Management, Inc. (“HCHK\nProperty”) was incorporated in Delaware. Yvette Wang was elected as the initial director of\nHCHK Property. See ¶ 21(e). On or about December 15, 2021, by written consent of the Board\nof Directors of HCHK Property (i.e., Wang), DiBattista was appointed Treasurer of HCHK\n25\n\nProperty. On or about January 1, 2022, Wang resigned and DiBattista was appointed as President,\nCEO, and Director of HCHK Property.\nd. DiBattista’s roles with various of the other GUO-affiliated entities included, among\nothers, Treasurer of GTV, authorized signatory of Lexington Property bank accounts, and\nTreasurer of G Music LLC.\ne. Based on my review of subpoena returns and my conversations with others, I have\nlearned that on or about July 18, 2021, a G Fashion HR employee sent a “transition memo” to Alex\nHadjicharalambous that, “[e]ffective as of July 19, 2021, all GFashion employees will have the\noption to transfer to GFashion’s staffing company, HCHK Technologies, Inc.,” which would\n“thereafter serve the role of staffing company for GFashion and other enterprises.” The transition\nmemo further reflected that an employee’s failure to execute the transition memo that same day\nwould result in termination.\nf. Based on my review of open-source Internet research and subpoena returns, I have\nlearned that one of the Directors of HCHK Technologies is also the Director and Chairman of the\nAudit Committee of Gettr,7 a social media platform that reportedly evolved from GTV Media. I have\nfurther learned that JE’s company, Hamilton, owns 95% of Gettr and contributed $35 million to Gettr\nin capital contribution.\ng. Based on the foregoing, I have learned that starting on or about July 19, 2021,\ncertain employees of G Fashion, Gettr, and other GUO-affiliated entities began to operate under\nthe company names HCHK Technologies and/or HCHK Property.\n7 See http\n(last visited July 6, 2022). Based on my conversations with others, I have learned that Gettr is one\nof the companies for which HCHK Technologies provides purported staffing services.\n26\n\nOverview of the Scheme to Launder Fraud Proceeds\n43. As described in greater detail herein, since at least in or about 2020, GUO, JE, and\nothers have operated the Investment Schemes, i.e., various interrelated fraudulent investment\nschemes. The Investment Schemes involve entities affiliated with GUO and/or JE, including GTV,\nG Fashion, G Club, Crane, Lamp Capital LLC, Hudson Diamond NY, Greenwich Land LLC,\nHCHK Technologies, the Himalaya Farms, the Himalaya Exchange, Hamilton, and ACA Capital,\namong others.\n44. As described above, between in or about April 2020 and June 2020, GUO, JE, and\nothers fraudulently obtained more than approximately $635 million in purported investments\nthrough the Unregistered Stock Offerings and Convertible Loan Offering. See supra ¶ 18.\nRecords that I or others have reviewed in the course of the Investigation show that, between in or\nabout November 2020 and June 2022, G Club has generated more than approximately $221 million\nin purported G Club membership fees.\n45. The evidence demonstrates that between at least approximately April 2020 and the\npresent, GUO, JE, and others have been engaged in a scheme to launder fraud proceeds from the\nInvestment Schemes (which include the Unregistered Stock Offerings, the Convertible Loan\nOffering, G Club, and the Himalaya Exchange) (collectively, the “Investment Scheme Funds”).\n46. As part of the money laundering scheme, JE and others have conducted financial\ntransactions totaling more than approximately $1.04 billion, as described in greater detail below.\n47. Investment Scheme Funds (specifically, Convertible Loan Offering funds), have\nbeen traced into the Target Account in ways that, based on my training and experience, are\nindicative of money laundering. Specifically, the tracing of the funds reflects, among other things,\nthe layering of Convertible Loan Offering funds through a series of entities and bank accounts, in\nsome cases pursuant to purported loan agreements or other financial arrangements.\n27\n\nUse of Multiple Banks and Financial Institutions to Conceal Investment Scheme Funds\n48. Based on my participation in this Investigation, training, experience, review and\nanalysis of various bank account records and financial analyses performed by me and financial\nanalysts at the FBI and SEC, open-source research that I have conducted on the Internet, my review\nof evidence obtained pursuant to subpoenas and judicially authorized search warrants, and my\nconversations with others, I have learned the following, among other things:\na. To date, law enforcement has identified more than at least 80 bank accounts\nbeing used by GUO, JE, and others to process Investment Scheme Funds, which include, among\nothers:\ni. At least approximately 19 bank accounts in the name of G Club\nentities (i.e., G Club International Limited or G Club Operations LLC) at approximately seven\ndifferent financial institutions;\nii. At least approximately 16 bank accounts in the name of Crane (i.e.,\nCrane Advisory Group LLC) at approximately six different financial institutions;\niii. At least approximately 28 bank accounts in the name of Farm\nentities at approximately six different financial institutions;\niv. At least approximately eight bank accounts in the name of G Fashion\nat approximately six different financial institutions;\nv. At least approximately 14 bank accounts in the name of Hamilton\nentities (e.g., Hamilton Investment Management Inc. or Hamilton Opportunity Funds SPC) at\nSilvergate Bank in California; and\nvi. At least approximately three bank accounts in the name of Himalaya\nentities (i.e., Himalaya Reserve, Himalaya Financial, and Himalaya Clearing) at FV Bank in Puerto\nRico.\n28\n\nTracing of Fraudulent Proceeds\n49. Based on my participation in this Investigation, training, experience, review and\nanalysis of various bank account records and financial analyses performed by me and financial\nanalysts at the FBI and SEC, open-source research that I have conducted on the Internet, my review\nof evidence obtained pursuant to subpoenas and judicially authorized search warrants, and my\nconversations with others, I have learned the following, among other things:\na. Investors have participated in the Investment Schemes (including the\nConvertible Loan Offering) by sending money to bank accounts controlled or used by GUO, JE,\nand others (including bank accounts in the names of the Farms’s entities, G Club, or Hamilton), or\nby wiring or otherwise transferring money to other entities at the direction of the Target Subjects.\nFor example, investors sent money to entities affiliated with a specific Farm (for example, to bank\naccount(s) in the name of Maywind for the Phoenix Farm), which funds are then transmitted to\nbank accounts ultimately controlled by GUO, GUO’s associates, and JE. I have discovered\naccounts located in the UAE, the United Kingdom, the United States, the Bahamas, and the British\nVirgin Islands, which GUO, JE, and other Target Subjects have used for the purpose of receiving\ninvestment funds from investors in the Unregistered Stock Offerings, the Convertible Loan\nOffering, G Club, and the Himalaya Exchange.\nb. To date, I and analysts at the FBI and SEC have identified and attempted to\ntrace more than approximately $1.04 billion in Investment Scheme Fund transactions, a substantial\npart of which has been laundered through financial institutions located in at least four different\ncountries, including the United States, the Bahamas, the British Virgin Islands, and the UAE.\nConvertible Loan Offering Proceeds are Transferred to the Phoenix Farm Accounts\n50. Based on my participation in this Investigation, my training and experience, my\nreview and analysis of various bank account records and financial analyses performed by me and\n29\n\nfinancial analysts at the FBI and SEC, open-source research that I have conducted on the Internet,\nmy review of evidence obtained pursuant to subpoenas and judicially authorized search warrants,\nmy review of an interview with a witness who worked at the Phoenix Farm (“Witness-1”), and my\nconversations with others, I have learned the following, among other things:\na. The Phoenix Farm began operating in or about September 2020. In or about\nlate September 2020, Yvette Wang and others visited individuals who operated the Phoenix Farm\nin Phoenix, Arizona. During the visit, Wang stated to Witness-1 and others, in sum and substance,\nthat GUO directed that “loan” investments sent to the Phoenix Farm entities (i.e., Maywind,\nMedical Supply, and Santel) should be moved around among bank accounts to avoid suspicion.\nSee also ¶ 41(a).\nb. Based on my review of an informal translation and transcription of a voice\nmessage that GUO sent to the SOI via WhatsApp, which was provided pursuant to a subpoena, I\nhave learned that GUO stated the following to the SOI, in substance and in part: “As for the three\ncompanies (Maywind, Santel, Medical supply), [SOI], you can discuss with [Yvette Wang] where\nto transfer the money to.”\nc. In or about August 2020, LI opened the Target Account under the name\n“G Fashion.” On or about August 13, 2020, LI added HAO as an authorized signer on the Target\nAccount.\nd. Between in or about September 2020 and on or about December 31, 2020,\nthe Target Account received approximately $9.9 million in Investment Scheme Funds from the\nPhoenix Farm bank accounts. Specifically:\ni. On or about September 30, 2020, approximately $1 million was\ntransferred from a JP Morgan Chase bank account in the name of Medical Supply System\nInternational LLC, ending in 9002, to the Target Account.\n30\n\nii. On or about November 19, 2020, approximately $2.9 million was\ntransferred from a Bank of America bank account in the name of Medical Supply System\nInternational LLC, ending in 3775, to the Target Account. Based on my review of the funds\ntransfer request authorization for the wire transfer, I have learned that the purpose of the payment\nwas listed as “Other / Additional Support Loans.”\niii. On or about December 1, 2020, approximately $3 million was\ntransferred from a JP Morgan Chase bank account in the name of Maywind Trading LLC, ending\nin 0414, to the Target Account.\niv. On or about December 10, 2020, approximately $3 million was\ntransferred from a JP Morgan Chase bank account in the name of Maywind Trading LLC, ending\nin 4311, to the Target Account.\nv. Aside from the above deposits, activity in the Target Account\nconsisted of de minimis service charges.\nvi. Based on my review of information provided by US Bank, I have\nlearned that the Target Account held approximately $9,899,785.06 as of on or about February 28,\n2022.\nIII. Conclusion\n51. Based on the foregoing, I submit that there is probable cause to believe that funds\nheld in the Target Account are subject to forfeiture as proceeds of violations of 18 U.S.C. § 1343\n(wire fraud) and § 1344 (bank fraud), and/or as property involved in violations of 18 U.S.C.\n§§1956(a)(1)(B)(i), 1956(a)(2)(B)(i), and 1956(h) (money laundering and conspiracy to commit\nmoney laundering).\n31\n\n52. Accordingly, pursuant to 18 U.S.C. § 981(b), I respectfully request that the Court\nissue a warrant authorizing the seizure of the funds held in the Target Account.\n/s/ Anthony Alecci, by SDA with permission\n________________________________\nANTHONY ALECCI\nSpecial Agent\nFederal Bureau of Investigation\nSworn to me through the transmission of this\nAffidavit by reliable electronic means, pursuant to\nFederal Rules of Criminal Procedure 41(d)(3) and 4.1,\nthis 18th day of September, 2022\n___________________________________\nTHE HONORABLE STEWART D. AARON\nUNITED STATES MAGISTRATE JUDGE\nSOUTHERN DISTRICT OF NEW YORK\n32","body_zh":null,"key_entities":[],"ecf_references":[],"word_count":9118,"status":"published","published_at":"2025-07-28 00:00:00","created_at":"2025-07-28","updated_at":"2026-07-06 20:56:38"}