{"id":"court_sdny_716_4","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 D\n\nUNITED STATES DISTRICT COURT 22 MAG 7684\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 Silvergate Warrant\nBank account 5090042853, held by Hamilton\nOpportunity Fund SPC (“Target Account-1”), Pursuant to 18 U.S.C. §§ 981 and 984\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in FV Bank\naccount 7801000589, held by Himalaya\nInternational Financial Group, Ltd. (“Target\nAccount-2”), and all funds traceable thereto,\nincluding accrued interest;\nAll monies and funds contained in FV Bank\naccount 7801000590, held by Himalaya\nInternational Reserves, Ltd. (“Target Account-\n3”), and all funds traceable thereto, including\naccrued interest; and\nAll monies and funds contained in FV Bank\naccount 7801000254, held by Himalaya\nInternational Clearing, Ltd. (“Target Account-\n4”), and all funds traceable thereto, including\naccrued interest (collectively, the “Target\nProperty”).\nDefendants-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.\n\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, for:\na. All monies and funds contained in Silvergate Bank account 5090042853,\nheld by Hamilton Opportunity Fund SPC (“Target Account-1”), and all funds traceable thereto,\nincluding accrued interest;\nb. All monies and funds contained in FV Bank account 7801000589, held by\nHimalaya International Financial Group, Ltd. (“Target Account-2”), and all funds traceable\nthereto, including accrued interest;\nc. All monies and funds contained in FV Bank account 7801000590, held by\nHimalaya International Reserves, Ltd. (“Target Account-3”), and all funds traceable thereto,\nincluding accrued interest; and\nd. All monies and funds contained in FV Bank account 7801000254, held by\nHimalaya International Clearing, Ltd. (“Target Account-4”), and all funds traceable thereto,\nincluding accrued interest (collectively, the “Target Property”).\n3. The Target Property 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\n2\n\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 herein, there is probable cause to believe that the Target Property is\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\n3\n\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 Property.\nII. Statutory Basis for Forfeiture\n7. The statutory provisions pursuant to which the Target Property 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 –\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.]\n4\n\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.”\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\n5\n\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.\nIII. Probable Cause\nA. Probable Cause Regarding Commission of the Subject Offenses\n16. On or about September 17, 2022, I submitted an affidavit in support of seizure\nwarrants for approximately 11 bank accounts, including approximately one Metropolitan\nCommercial Bank (“MCB”) account, held at For Benefit Of FV Bank, and approximately nine\n6\n\nSilvergate Bank (“Silvergate”) accounts, held by William JE in the name of Hamilton Opportunity\nFund SPC or Hamilton Investment Management Ltd. (the “September 17 Affidavit”). The\nSeptember 17 Affidavit is incorporated herein as Exhibit A. On or about September 18, 2022, the\nHonorable Stewart D. Aaron issued seizure warrants for those 11 accounts, including a warrant to\nSilvergate for the nine Silvergate accounts (the “Silvergate Warrant”) and a warrant to MCB for\nthe one MCB account held For Benefit Of FV Bank (the “MCB Warrant”).\n17. In coordinating with Silvergate in anticipation of the service and execution of the\nSilvergate Warrant, Silvergate provided updated account balances for all Silvergate accounts in\nthe name of Hamilton Opportunity Fund SPC and/or Hamilton Investment Management Ltd.\nBased on my review of account balance summaries, additional documents provided by Silvergate\nBank, open-source information, and my conversations with the U.S. Attorney’s Office for the\nSouthern District of New York, I have learned the following, among other things:\na. Silvergate operates an intra-bank network called the Silvergate Exchange\nNetwork, or “SEN.” Active bank clients with Silvergate can participate in SEN, which enables\nSilvergate clients themselves to transfer money between their Silvergate accounts and the accounts\nof other Silvergate clients.\nb. The Silvergate business deposit account master agreement for the Hamilton\nOpportunity Fund SPC relationship at Silvergate lists Target Account-1 as a SEN account. Based\non information provided by Silvergate, I have learned that the account balance of Target Account-\n1 as of on or about August 31, 2022 was $0.\nc. As reflected in the September 17 Affidavit, the balance of the Hamilton\nInvestment Opportunity Fund SPC account at Silvergate ending in -2762 (i.e., “Target Account-\n6” in the September 17 Affidavit, or the “2762 Account”) was approximately $76,690,856.60. On\nor about September 8, 2022, the 2762 Account received incoming transfers from HCHK\n7\n\nTechnologies Inc. and HCHK Property Management Inc., respectively, each in the amount of $5\nmillion.\nd. On or about September 15, 2022, the Target Subjects transferred\napproximately $85,899,889.20—nearly the entire balance—from the 2762 Account to Target\nAccount-1. As described in the September 17 Affidavit, the nature of the transfers of funds into\nthe 2762 Account had been consistent with money laundering, including layering funds through\ndifferent entities and concealing their true source and/or purpose. See Sept. Aff. at ¶ 56(b)(v), (f).\n18. In coordinating with MCB and counsel for FV Bank in anticipation of the service\nand execution of the MCB Warrant, counsel for both MCB and FV Bank advised law enforcement\nof the following, in sum and substance:\na. The funds held in the pooled MCB account FBO FV Bank (i.e., “Target\nAccount-11” in the September 17, 2022 Affidavit) include funds belonging to all FV Bank’s\ncustomers, not only the Himalaya entities. See Sept. Aff. at ¶¶ 59(i)(3), 62.\nb. The funds that were the target of the MCB Warrant, held in the MCB pooled\naccount, were also identified by three particular FV Bank account numbers: Target Account-2\n(i.e., FV Bank account 7801000589, held by Himalaya International Financial Group, Ltd.),\nTarget Account-3 (i.e., FV Bank account 7801000590, held by Himalaya International Reserves,\nLtd., and Target Account-4 (i.e., FV Bank account 7801000254, held by Himalaya International\nClearing, Ltd.).\n19. Based on the foregoing information, law enforcement will not execute the MCB\nWarrant and instead seeks to direct the warrant to FV Bank.\nIII. Conclusion\n20. Based on the information set forth in the September 17 Affidavit and the foregoing,\nI submit that there is probable cause to believe that funds held in the Target Property are subject\n8\n\nto forfeiture as proceeds of violations of 18 U.S.C. § 1343 (wire fraud) and § 1344 (bank fraud),\nand/or as property involved in violations of 18 U.S.C. §§ 1956(a)(1)(B)(i), 1956(a)(2)(B)(i), and\n1956(h) (money laundering and conspiracy to commit money laundering).\n21. Accordingly, pursuant to 18 U.S.C. § 981(b), I respectfully request that the Court\nissue a warrant authorizing the seizure of the Target Property.\n_/s_/_ A__n_th_o_n_y_ _A_l_e_cc_i_, _b_y_ S_D__A_ _w_i_th_ permission\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, this\n2_0_ day of September, 2022\n_____________________________________\nTHE HONORABLE STEWART D. AARON\nUNITED STATES MAGISTRATE JUDGE\nSOUTHERN DISTRICT OF NEW YORK\n9\n\nEXHIBIT A\n\n22 MAG 7580\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 Silvergate Warrant\nBank account 5090037739, held by Hamilton\nOpportunity Fund SPC (“Target Account-1”), Pursuant to 18 U.S.C. §§ 981 and 984\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in Silvergate\nBank account 5090037705, held by Hamilton\nOpportunity Fund SPC (“Target Account-2”),\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in Silvergate\nBank account 5090037754, held by Hamilton\nOpportunity Fund SPC (“Target Account-3”),\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in Silvergate\nBank account 5090037713, held by Hamilton\nOpportunity Fund SPC (“Target Account-4”),\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in Silvergate\nBank account 5090042770, held by Hamilton\nOpportunity Fund SPC (“Target Account-5”),\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in Silvergate\nBank account 5090042762, held by Hamilton\nOpportunity Fund SPC (“Target Account-6”),\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in Silvergate\nBank account 5090042820, held by Hamilton\nOpportunity Fund SPC (“Target Account-7”),\n\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in Silvergate\nBank account 5090042747, held by Hamilton\nOpportunity Fund SPC (“Target Account-8”),\nand all funds traceable thereto, including\naccrued interest;\nAll monies and funds contained in Silvergate\nBank account 5090030288, held by Hamilton\nInvestment Management Ltd. (“Target Account-\n9”), and all funds traceable thereto, including\naccrued interest;\nAny and all monies and funds up to and\nincluding the sum of $16,000,000.00 contained\nin Manufacturers & Traders Trust Co. account\n9878904409, held by GETTR USA, Inc.\n(“Target Account-10”), and all funds traceable\nthereto, including accrued interest; and\nAll monies and funds contained in Metropolitan\nCommercial Bank account 0299006891, held\nFor Benefit Of FV Bank (“Target Account-11”),\nand all funds traceable thereto, including\naccrued interest (collectively, the “Target\nProperty”).\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\n2\n\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:\na. All monies and funds contained in Silvergate Bank account 5090037739,\nheld by Hamilton Opportunity Fund SPC (“Target Account-1”), and all funds traceable thereto,\nincluding accrued interest;\nb. All monies and funds contained in Silvergate Bank account 5090037705,\nheld by Hamilton Opportunity Fund SPC (“Target Account-2”), and all funds traceable thereto,\nincluding accrued interest;\nc. All monies and funds contained in Silvergate Bank account 5090037754,\nheld by Hamilton Opportunity Fund SPC (“Target Account-3”), and all funds traceable thereto,\nincluding accrued interest;\nd. All monies and funds contained in Silvergate Bank account 5090037713,\nheld by Hamilton Opportunity Fund SPC (“Target Account-4”), and all funds traceable thereto,\nincluding accrued interest;\ne. All monies and funds contained in Silvergate Bank account 5090042770,\nheld by Hamilton Opportunity Fund SPC (“Target Account-5”), and all funds traceable thereto,\nincluding accrued interest;\nf. All monies and funds contained in Silvergate Bank account 5090042762,\nheld by Hamilton Opportunity Fund SPC (“Target Account-6”), and all funds traceable thereto,\n3\n\nincluding accrued interest;\ng. All monies and funds contained in Silvergate Bank account 5090042820,\nheld by Hamilton Opportunity Fund SPC (“Target Account-7”), and all funds traceable thereto,\nincluding accrued interest;\nh. All monies and funds contained in Silvergate Bank account 5090042747,\nheld by Hamilton Opportunity Fund SPC (“Target Account-8”), and all funds traceable thereto,\nincluding accrued interest; and\ni. All monies and funds contained in Silvergate Bank account 5090030288,\nheld by Hamilton Investment Management Ltd. (“Target Account-9”), and all funds traceable\nthereto, including accrued interest;\nj. Any and all monies and funds up to and including the sum of\n$16,000,000.00 contained in Manufacturers & Traders Trust Co. account 9878904409, held by\nGETTR USA, Inc. (“Target Account-10”), and all funds traceable thereto, including accrued\ninterest; and\nk. All monies and funds contained in Metropolitan Commercial Bank account\n0299006891, held For Benefit Of (“FBO”) FV Bank (“Target Account-11”), and all funds\ntraceable thereto, including accrued interest (collectively, the “Target Property”).\n3. The Target Property 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\n4\n\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 Property is\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\n5\n\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 Property.\nII. Statutory Basis for Forfeiture\n7. The statutory provisions pursuant to which the Target Property 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 –\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\n6\n\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.”\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\n7\n\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.\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”)\n8\n\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. Certain of the interrelated Investment Schemes are historical, while others are\nongoing. 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\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.\n9\n\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). As described below,\nG Club and the Himalaya Exchange have raised at least approximately $664 million between in or\nabout September 2020 and the present.\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.\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\n1 See http\n(describing Guo and Bannon’s involvement in the “Rule of Law Fund”).\n10\n\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\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\n2 See http\n3 See http\n11\n\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.\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\n12\n\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\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 (“SOI4”) involved\nwith the ROLF, the Companies, the GTV Stock Offering, and the Phoenix Farm, as well as my\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.\n13\n\nreview of the metadata of the Memorandum, I have learned that JE was a primary author of the\nMemorandum.\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),\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\n14\n\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\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:\n15\n\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\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\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.\n16\n\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\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.\n17\n\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:\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\n18\n\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.\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\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.”\n19\n\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. The\nFarms were typically referred to by the names of preexisting companies that they affiliated\nthemselves with for banking purposes; e.g., Mountains of Spices LLC and Davy & Tony\nInternational Limited for the New York Farm, and Maywind Trading LLC, Medical Supply\nSystem International LLC and Santel LLC for the Phoenix Farm.\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\n20\n\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\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.\n21\n\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;\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\n22\n\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:\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\n23\n\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\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.\n24\n\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.\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).\n25\n\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\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, 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.”\n26\n\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\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.\n27\n\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\nhave further learned that JE’s company, Hamilton, owns 95% of Gettr and contributed $35 million\nto Gettr in 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.\nThe Himalaya Exchange Scheme\n42. As described above, JE founded a purported cryptocurrency exchange platform\ncalled Himalaya Exchange, available at http (the “Himalaya Exchange\nWebsite”). Similar to the link between G-Coin / G-Dollar and the Unregistered Stock Offerings,\nHimalaya Coin (ticker: HCO or HCN) and Himalaya Dollar (ticker: HDO) (together, the\n“Himalaya Assets”) were initially offered as a companion digital asset security for investors in the\nConvertible Loan Program.\n43. Based on my participation in this investigation, training, experience, review of the\nHimalaya Exchange Website, videos posted on GNews, bank records and subpoena returns, and\nopen-source research that I have conducted on the Internet, as well as my conversations with\nothers, including law enforcement and witnesses, I have learned the following, among other things:\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.\n28\n\na. The Himalaya Exchange is described as a global digital exchange with a\nfull ecosystem, that includes (or will include) a stablecoin (Himalaya Dollar),8 a trading coin\n(Himalaya Coin), and a blockchain payment application called “Himalaya Pay.”\nb. JE is described as the founder and Chairman of the Himalaya Exchange.\nc. As described above, JE is also the founder and CEO of BVI-based\nHamilton and the Director of Hong Kong-based ACA Capital.\nd. An image from the Himalaya Exchange Website, viewable at\nhttp is shown below:\n44. Based on my participation in this Investigation, training, experience, review of the\nHimalaya Exchange Website, videos posted on GNews, bank records and subpoena returns, and\nopen-source research that I have conducted on the Internet, as well as my conversations with\nothers, including law enforcement and witnesses, I have learned, among other things, that investors\n8 A stablecoin is a cryptocurrency that seeks to peg itself to a stable currency, typically the U.S.\ndollar.\n29\n\nwere misled about how and when they would be able to trade their cryptocurrency assets.\nSpecifically:\na. When the Himalaya Exchange Website was launched, investors were told\nthat, as of June 2021, they would be able to exchange and withdraw their cryptocurrency. An\nimage of the website from May 2021 depicting this representation is shown below:\nb. The Himalaya Exchange Website later changed its “trade” date to September 2021.\nBased on my training, experience, and participation in this investigation, I have learned that it is\ncommon for fraudulent cryptocurrencies to use similar tactics to those used here; specifically it is\ncommon for fraudulent cryptocurrencies to: (1) not be tradable on a public exchange; and\n(2)induce investors to purchase the cryptocurrencies through false promises that the\ncryptocurrency will be available to trade on a public exchange soon.\nc. The initial coin offering (“ICO”) of the Himalaya Assets purportedly took place on\nthe Himalaya Exchange Website or about November 1, 2021. According to data on the Himalaya\nExchange Website, the price of a Himalaya Asset increased from 10 cents at the time of the ICO\nto $27 approximately two weeks later, resulting in a purported $27 billion valuation by mid-\nNovember 2021, as reflected in the graph below from the Himalaya Exchange Website:\n30\n\nd. According to Himalaya Exchange’s promotional materials, the value of the\nHimalaya Dollar is pegged to the U.S. Dollar. “Credits” are used to secure positions within the\nHimalaya Ecosystem, which positions correspond to a particular type of crypto asset. Promotional\nmaterials also state that “[c]redits can only be used on the Himalaya Exchange or within the\nHimalaya Ecosystem, representing a right to participating in trading on the Himalaya\nExchange and do not carry any right to require their exchange for fiat currency or crypto-assets.”\nPromotional materials clarify that references to Himalaya Coin, Himalaya Dollar, “or any other\ntype of asset on an account at the Himalaya Exchange or through the Himalaya Pay App are\nreferences to Credits corresponding to that asset.”\ne. According to the Himalaya Dollar whitepaper dated April 2021 (the “Whitepaper”),\navailable on the Himalaya Exchange Website, Himalaya Dollar is an Ethereum-\nbased token “structured with the aim of maintaining its value 1-to-1 to the United States Dollar.\n31\n\nHimalaya Dollar Credits benefit from potential liquidity support which may be provided through\nthe [Himalaya] Reserve which will be managed with the aim of maintaining its value at a level\nequal in value in U.S. dollars to the value of Himalaya Dollars in circulation as described below.”\nf. The Whitepaper further states that Himalaya Reserves, the issuer of Himalaya\nDollar, “intends to create and hold in the Reserve a mix of United States dollars or other currencies\nin cash and cash equivalents,” and further states, “it is intended to make the Reserve transparent\nto the public. The Issuer intends to have the Reserve audited annually by independent auditors.\nThe results of those audits will be made publicly available with details of the then-current\ncomposition of the Reserve and the market value of the assets as at[sic] the time of publication.”\nTo date, no such audit results have been published.\ng. As described above, the Himalaya Assets have never traded on an open exchange,\nand instead purport to trade only on the private Himalaya Exchange. Himalaya Exchange restrains\nthe flow of real currency out of the Himalaya Exchange by its members, as described above. Thus,\nthe ability to convert Himalaya Dollars and Himalaya Coins back into U.S. currency was limited.\n45. Based on my participation in this investigation, training, experience, review of the\nHimalaya Exchange Website, videos posted on GNews, and public source research that I have\nconducted on the Internet, as well as my conversations with others, I have learned the following,\namong other things:\na. As described above, Himalaya Dollar purports to be a “stablecoin” that is\npegged 1-to-1 to the value of the U.S. dollar. Other major stablecoins include TerraUSD, Tether,\nand USD Coin.\nb. In a video summary posted on GNews in November 2021, GUO\nrepresented, in sum and substance, that Himalaya Coin was backed by the U.S. dollar through\n32\n\nstablecoin Himalaya Dollar, and further stated that Himalaya Coin is backed by a reserve of 20%\nof the proceeds in gold.\nc. In or about May 2022, there was a global stablecoin collapse that began\nwhen a particular stablecoin called TerraUSD lost its peg (i.e., no longer had sufficient hard-asset\nreserves to back its cryptocurrency at a 1-to-1 ratio to the U.S. dollar). As a result, the\ncryptocurrency market lost approximately $300 billion in value. The valuation of TerraUSD\nthrough May 10, 2022 is reflected in the graph below:\nd. In contrast, data on the Himalaya Exchange Website reflects very little\nfluctuation or decrease in the purported value of the Himalaya Assets during the same time period,\nas reflected in the graph below from the Himalaya Exchange Website:\n33\n\n46. I have reviewed the graph displayed above in paragraphs 44(c), showing the value\nof the Himalaya Assets’ purported value between approximately November 1, 2021 and December\n31, 2021. The graph is consistent with the purported price of the Himalaya Assets being falsified—\nspecifically, it reflects a steep increase in price over the first two weeks and then an apparent\nfluctuation in price, but all within a narrow band.\n47. I have also reviewed the graphs displayed above in paragraphs 45(c) and (d),\nreflecting the price of stablecoin TerraUSD and the purported price of a Himalaya Asset between\nApril 2021 and May 10, 2021. The data reflected in the Himalaya Asset graph is inconsistent with\nthe valuation of other stablecoins, including TerraUSD, during the stablecoin crash.9\n9 On or about June 15, 2022, it was reported that William Je said the following: “Despite the\ncryptocurrency market’s recent dip, HDO has constantly remained stable with the US dollar 1:1\nwithout fluctuation. Impressively, this makes HDO the only stable coin in the world to maintain\n100% during this time-period of uncertainty.” See http\nreleases/iconic-ferrari-f1-car-sold-by-rm-sotheby-s-using-cryptocurrency-himalaya-dollar-\n883914213.html (last visited July 6, 2022)\n34\n\nOverview of the Scheme to Launder Fraud Proceeds\n48. 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.\n49. 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.\n50. As detailed below, the evidence demonstrates that between at least approximately\nApril 2020 and the present, GUO, JE, and others have been engaged in a scheme to launder fraud\nproceeds from the Investment Schemes (which include the Unregistered Stock Offerings, the\nConvertible Loan Offering, G Club, and the Himalaya Exchange) (collectively, the “Investment\nScheme Funds”).\n51. 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.\n52. As a further part of the money laundering scheme, at least approximately $252\nmillion of the Investment Scheme Funds were remitted, either directly or indirectly, to bank\naccounts in the United States and the Bahamas held in the name of JE’s companies—Hamilton,\nACA Capital, and Himalaya Exchange—or otherwise controlled by JE.\n35\n\n53. In particular, as described below, JE opened certain of the Target Accounts and\nother bank accounts at Silvergate Bank, a bank in La Jolla, California that markets itself as “the\nleading bank for innovative business in fintech and cryptocurrency.” Target Accounts-1 through\n-8 are in the name of a Cayman Islands-registered hedge fund, Hamilton Opportunity Fund SPC;\nTarget Account-9 is in the name of JE’s company, Hamilton Investment Management Ltd., which\ncompany is the investment manager of the Hamilton Opportunity Fund SPC. JE is the principal\nof Hamilton Investment Management Ltd. and an authorized signer on the Silvergate Target\nAccounts.\n54. As further described below, JE opened three accounts at FV Bank, a bank in Puerto\nRico that markets itself as “The Global Digital Bank.” The FV Bank accounts are in the names\nof various legal entities through which JE and others operate the Himalaya Exchange—Himalaya\nClearing, Himalaya Financial, and Himalaya Reserves. JE is the ultimate beneficial owner of those\nHimalaya legal entities, see supra ¶ 19(d), and is an authorized signer on the FV accounts.\n55. Investment Scheme Funds have been traced into and among the Target Accounts\nin ways that, based on my training and experience, are indicative of money laundering.\nSpecifically, the tracing of the funds reflects, among other things: (a) transfers of Investment\nScheme Funds from U.S. bank accounts to bank accounts located overseas (including the UAE\nand the Bahamas) in high risk jurisdictions that are frequent havens for money laundering;\n(b)layering of Investment Scheme Funds through a series of entities and bank accounts, in some\ncases pursuant to purported loan agreements or other financial arrangements, in a manner\nconsistent with concealment of the nature, source, or origin of the funds; (c) investments in real\nestate or other business interests that have no apparent connection with the stated purposes of the\nbusinesses controlling the bank accounts; and (d) the transfer of Investment Scheme Funds\nbetween multiple banks, as well as among multiple accounts within the same bank, in a single day.\n36\n\nUse of Multiple Banks and Financial Institutions to Conceal Investment Scheme Funds\n56. 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.\n37\n\nb. In addition to utilizing bank accounts held in the names of entities owned or\ncontrolled by JE and others directly involved in the Investment Schemes, GUO, JE, and others\nlayer Investment Scheme Funds through accounts at other financial institutions and third-party\npayment management entities to conceal the nature and source of the funds. For example, and as\ndescribed in greater detail herein:\ni. BSI Group LLC (“BSI Group”) is a Missouri-based company that\noffers payment agreement services. Based on my conversations with others, I have learned that\nBSI Group effectively operates as a wholesaler and opens bank accounts at U.S.-based financial\ninstitutions for its customers. U.S. banks that BSI Group contracts with include Capital One, The\nReserve Trust Company (“Reserve Trust”), Prime Trust LLC (“Prime Trust”), and a Puerto Rico-\nbased financial institution called Mercantile Bank International Corp. and its affiliated entities\n(“Mercantile Bank” or “MBI”). BSI Group is a client of Capital One, Reserve Trust, and Prime\nTrust, among other entities, while MBI is one of BSI Group’s customers.\nii. BSI Group manages transactions on behalf of its own customers,\nincluding MBI. BSI Group’s customers direct the movement of their funds—which are held in\naccounts in the name of BSI Group and/or Reserve Trust and Prime Trust—by requesting\ntransactions through BSI Group’s website (e.g., indicating the originator, payee, and amount for a\nspecific transaction).\niii. GUO, JE, and others have laundered more than approximately $300\nmillion in Investment Scheme Funds through bank accounts held in the names of various financial\nintermediary companies, including BSI Group, Reserve Trust, and Prime Trust. GUO, JE, and\nothers have also layered Investment Scheme Funds through bank accounts held at various different\nfinancial institutions.\n38\n\niv. For example, on or about May 20, 2021, G Club’s financial\ncontroller, Alex Hadjicharalambolous, exchanged emails with employees at Puerto Rico-based\nfinancial institutions Medici Bank and MBI regarding a $15 million wire transfer of G Club\nInvestment Scheme Funds from a bank account in the name of BSI Group to a bank account in the\nname of Hamilton Opportunity Fund SPC at Deltec Bank & Trust (“Deltec”), which is located in\nthe Bahamas (the “Hamilton Bahamas Account”). The next day, David Fallon (the President of\nHamilton) emailed Hajicharalmbous to advise that Hamilton could not credit the wire to G Club,\nbecause the wire reflected that the sender was “BSI Group.”\nv. Hadjicharalambous forwarded the email to an MBI employee, who\nthen responded to Hadjicharalmbous (copying Fallon) with the following explanation, in substance\nand in part:\nHI guys, so flow of funds is as follows. It’s a little detailed here so apologies.\nThe wire comes from BSI group ( MBIs corresponding bank partner)to Deltec\n(Hamilton)\nThe accounts are as follows\nBSI/MBI have an account at Capital one, it is an MBI Bank escrow account owned\nby MBI. BSI does the processing for us.\nMedici is a client of MBI for this 15mm dollar transaction, Medici has an account\nwith MBI at Capital one\nGCLUB is a client of Medici.\nGclubs clients send money to the MBI account at Capital one denoted for GClub\n(through medici). Medici ledgers each wire as they come into the bank.\nTo solve below request, what exactly do you need to show the fund admin? Proof\nof account ownership or money inflow (source of funds)\nFor going forward activity, GClub is now a direct client of MBI, so wires will be\nsent from GClubs account at MBI, but the wires will always come from BSI as the\nMBI corresponding bank . We (MBI bank) will have the flow of funds from GClub\nclient to the account, so we will have the ability to trace the full flow of funds in\nand out of the GCLUB account.\n39\n\nvi. Similarly, on or about July 1, 2021, Hadjicharalambolous sent an\nemail to an employee at Medici Bank, directing Medici Bank to transfer approximately $4 million\nfrom a G Club Medici Bank account to a G Club MBI account. The wire instructions attached to\nthe email identify MBI as the beneficiary entity, but list Reserve Trust as the beneficiary bank.\nvii. Based on my participation in this Investigation, I believe that the\nforegoing explanation is an example of the manner in which GUO, JE, and others launder\nInvestment Scheme Funds through multiple financial institutions in an effort to, among other\nthings, conceal their source. See ¶ 56(b)(3).\nTracing of Fraudulent Proceeds\n57. 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 participate in the Investment Schemes by either wiring money\ndirectly to a bank account controlled or used by entities affiliated with GUO, JE, and others\n(including the Farms, G Club, or the Himalaya Exchange), or by wiring or otherwise transferring\nmoney to other entities at the direction of the Target Subjects (including, for example, Crane, BSI\nGroup, Reserve Trust, or Prime Trust), which funds are then transmitted to bank accounts\nultimately controlled by GUO, GUO’s associates, and JE. I have discovered accounts located in\nthe UAE, the United Kingdom, the United States, the Bahamas, and the British Virgin Islands,\nwhich GUO, JE, and other Target Subjects have used for the purpose of receiving investment funds\nfrom investors in the Unregistered Stock Offerings, the Convertible Loan Offering, G Club, and\nthe Himalaya Exchange.\n40\n\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.\nFraud Proceeds are Combined in Hamilton Bahamas Account Before Transfer to Certain of the\nSilvergate Target Accounts\n58. 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. Between in or about May 2021 and June 2021, approximately $100 million\nin Investment Scheme Funds were transferred from G Club bank accounts into the Hamilton\nBahamas Account. Before the approximately $100 million was combined in the Hamilton\nBahamas Account, the Investment Scheme Funds were layered through a series of entities at\nvarious different banks in a manner that, based on my training and experience, is indicative of\nmoney laundering. Specifically:\ni. As described above, certain prospective Investment Scheme\ninvestors were instructed to send funds intended as an investment in GTV (for example) to a bank\naccount in the name of Crane. See supra at ¶ 40(f). Approximately $78.2 million of Investment\nScheme Funds was sent from individual or institutional investors in China and elsewhere to two\nCrane Advisory bank accounts (the “Crane Citibank Accounts”) between in or about November\n2020 and April 2021.\n41\n\nii. Approximately $60 million of those Investment Scheme Funds were\nthen transferred from the Crane Citibank Accounts to approximately five different bank accounts\nat MSSB held in the name of Crane (together, the “Crane MSSB Accounts”).\niii. The approximately $60 million in Investment Scheme Funds from\nthe Crane MSSB Accounts was combined with approximately $49 million in other Investment\nScheme Funds that had been transferred into the Crane MSSB Accounts from two Crane accounts\nat a different bank, Capital One (together, the “Crane Capital One Accounts”), raising the total\ncombined balance in the Crane MSSB Accounts to approximately $109 million.\niv. Approximately $79 million of those approximately $109 million in\nInvestment Scheme Funds in the Crane MSSB Accounts were then transferred to accounts at the\nsame bank (i.e., MSSB), but in the name of G Club (i.e., the G Club MSSB Accounts). The\napproximately $79 million was combined with approximately $79.7 million in other Investment\nScheme Funds that had been transferred into the G Club MSSB Accounts from individual G Club\nInvestors and from G Club bank accounts at Signature Bank, First Bank of Puerto Rico, and City\nNational Bank, raising the total combined balance of Investment Scheme Funds in the G Club\nMSSB Accounts to more than approximately $158 million.\nv. Approximately $85 million of Investment Scheme Funds was\ntransferred from the G Club MSSB Accounts to the Hamilton Bahamas Account, and combined\nwith approximately $15 million in other Investment Scheme Funds (relating to G Club and the\nHimalaya Assets) sourced from a bank account in the name of BSI Group. See ¶ 56(b)(v). Thus,\nthe $100 million of Investment Scheme Funds in the Hamilton Bahamas Account consisted of\n42\n\nfunds transferred from the G Club MSSB Accounts and other accounts containing Investment\nScheme Funds.\nFraud Proceeds are Transferred to Silvergate Bank\n59. 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. On or about July 5, 2021, JE submitted a business bank account application\nto Silvergate Bank (the “Silvergate Application”) in the name of Hamilton Opportunity Funds\nSPC. JE’s company, Hamilton, is the investment manager of the Cayman Islands-registered hedge\nfund, Hamilton Investment Opportunity SPC. Between in or about July 2021 and the present, JE\nopened more than approximately 14 bank accounts at Silvergate Bank in the name of various\nHamilton-affiliated hedge funds or entities, including Hamilton Investment Opportunity SPC and\nHamilton Digital Assets Fund SP, and at least four bank accounts at Silvergate Bank in the name\nof Himalaya International Clearing Ltd. See ¶ 19(d)(iii).\nb. Between on or about September 1, 2021 and on or about July 5, 2022, JE-\ncontrolled Silvergate Bank accounts received approximately $664 million in Investment Scheme\nFunds. Specifically:\ni. In or about September 2021, approximately $85 million of the\nInvestment Scheme Funds was transferred from the Hamilton Bahamas Account, see supra at\n¶ 56(b)(iv), to a Silvergate Bank account in the name of Hamilton Opportunity Fund SPC, ending\nin 9306 (the “9306 Silvergate Account”). The approximately $85 million was combined with\napproximately $25 million in Investment Scheme Funds sourced from a bank account in the name\n43\n\nof Himalaya International Clearing Ltd. at a bank in the Bahamas (the “Himalaya Bahamas\nAccount”). Thus, as of in or about late September 2021, the 9306 Silvergate Account held at least\napproximately $110 million in Investment Scheme Funds.\nii. On or about October 27, 2021, approximately $59 million of the\napproximately $110 million in Investment Scheme Funds was transferred from the 9306 Silvergate\nAccount to a Silvergate Bank account in the name of Hamilton Digital Assets, ending in 7747 (the\n“7747 Silvergate Account”). Later that same day, the approximately $59 million was transferred\nfrom the 7747 Silvergate Account to Target Account-1 (i.e., a Silvergate Bank account in the\nname of Hamilton Opportunity Fund SPC, ending in 7739).\niii. Also on or about October 27, 2021, approximately $25 million of\nthe approximately $110 million was transferred from the 9306 Silvergate Account to Target\nAccount-2 (i.e., a Silvergate Bank account in the name of Hamilton Opportunity Fund SPC,\nending in 7705). As described in greater detail below, once received in Target Account-2, the\nmonies were combined with approximately $50 million in Himalaya Asset Investor Funds sourced\nfrom an FV Bank account in the name of Himalaya International Clearing Ltd., ending in 3763\n(the “3763 FV Account”).\n1. Approximately $30 million of the $50 million transferred\nfrom the 3763 FV Account into Target Account-2 can be traced to the approximately $110 million\nin Investment Scheme Funds that had been held in the 9306 Silvergate Account. That is, while\napproximately $25 million of the $110 million was transferred directly to Target Account-2 on\nor about October 27, 2021, an additional $30 million of the approximately $110 million was\ntransferred into Target Account-2 only after passing through three other bank accounts: the 7747\nSilvergate Account (held in the name of Hamilton Digital Assets), then Target Account-1 (held\n44\n\nin the name Hamilton Opportunity Fund SPC), and finally the 3763 FV Account (held in the name\nof Himalaya International Clearing Ltd.).\niv. Also on or about October 27, 2021, approximately $26 million of\nthe approximately $110 million was transferred from the 9306 Silvergate Account to a Silvergate\nBank account in the name of Hamilton Diversified Trading Fund, ending in 7762 (the “7762\nSilvergate Account”). Later that same day, the approximately $26 million was transferred from\nthe 7762 Silvergate Account to Target Account-3 (i.e., a Silvergate Bank account in the name of\nHamilton Opportunity Fund SPC, ending in 7754). Approximately two months later, on or about\nJanuary 4, 2022, approximately $26 million was transferred from Target Account-3 to the UAE\nACA Capital Account (i.e., an offshore bank account controlled by JE). See ¶¶ 32, 34.\nc. On or about December 2, 2021, approximately $46.5 million in Investment\nScheme Funds was transferred from Target Account-1 to Target Account-4 (i.e., a Silvergate\nBank account in the name of Hamilton Opportunity Fund SPC, ending in 7713). Once received in\nTarget Account-4, the monies were combined with approximately $5.6 million in Investment\nScheme Funds sourced from the Himalaya Bahamas Account (which funds passed through a\nSilvergate Bank account in the name of Hamilton PE Fund SP, ending in 7721), raising the\ncombined balance of Target Account-4 to approximately $52.1 million.\nd. On or about December 17, 2021, approximately $24.5 million of the\napproximately $52.1 million in Investment Scheme Funds was transferred from Target Account-\n4 to a bank account in the name of Insight Title Services LLC Trust AC; the stated purpose of the\ntransaction was for the purchase of residential property in Mahwah, New Jersey on behalf of an\nentity called Taurus Fund SP. Based on my review of a corporate resolution signed by JE, I have\nlearned that Taurus Fund SP is a segregated portfolio of Hamilton Opportunity Fund SPC (i.e.,\nthat JE controls Taurus Fund SP).\n45\n\ne. Between at least on or about January 24, 2022 and on or about April 4, 2022,\napproximately $73.8 million of Investment Scheme Funds was transferred into Target Account-\n5 (i.e., a Silvergate Bank account in the name of Hamilton Opportunity Fund SPC, ending in 2770).\nThe incoming transfers into Target Account-5 consisted primarily of wires ranging between\napproximately $1,100 to approximately $3 million from Chinese individuals, with some\nindividuals sending multiple incoming wires. Based on my participation in this investigation and\nmy training and experience, I believe the transfers into Target Account-5 are consistent with\nmoney laundering, including layering funds through different entities—for example, directing\ninvestor funds into a bank account in the names of an entity other than the intended investment\nvehicle, which here would be G Club or Himalaya Exchange. I further believe that the incoming\ntransfers are consistent with G Club investors purchasing multiple memberships, and therefore are\nfraud proceeds. See ¶ 40(g).\nf. Between on or about March 10, 2022 and on or about April 1, 2022,\napproximately $77,998,889.20 million in Investment Scheme Funds was transferred from bank\naccounts in the name of HCHK Technologies or HCHK Property into Target Account-6 (i.e., a\nSilvergate Bank account in the name of Hamilton Opportunity Fund SPC, ending in 2762). As\ndescribed above, starting in or about July 2021, various GUO-affiliated entities began to operate\nunder the newly-formed companies HCHK Technologies and HCHK Property. See ¶ 41. Based\non my participation in this investigation and my training and experience, and as described above,\nI believe the nature of the transfers into Target Account-6 are consistent with money laundering,\nincluding layering funds through different entities and concealing their true source and/or purpose.\nSee, e.g., ¶ 56(b)(v).\ng. The Investment Scheme Funds were traced into Target Account-7 and\nTarget Account-8 in the following manner:\n46\n\ni. On or about January 31, 2022, approximately $5.1 million in\nInvestment Scheme Funds was transferred from a bank account in the name of a particular Chinese\ninvestor (“Investor-2”) into Target Account-7 (i.e., a Silvergate Bank account in the name of\nHamilton Opportunity Fund SPC, ending in 2820).\nii. Between on or about January 31, 2022 and on or about February 4,\n2022, approximately $1 million in Investment Scheme Funds was transferred from bank accounts\nin the names of two particular Chinese investors (“Investor-3” and “Investor-4”) into Target\nAccount-8 (i.e., a Silvergate Bank account in the name of Hamilton Opportunity Fund SPC,\nending in 2747).\niii. Based on my review of subpoena returns and search warrant returns,\nI have learned that Investor-2 through -4 had previously invested in the GTV Stock Offering and/or\nthe other Investment Schemes. Specifically:\n1. According to a spreadsheet GTV maintained of more than\napproximately 1,200 investors in the GTV Stock Offering, Investor-2, Investor-3, and Investor-4\neach purchased GTV stock; Investor-2 purchased approximately 3.3 million shares, Investor-3\npurchased approximately 2 million shares, and Investor-4 purchased approximately 800,000\nshares.\n2. On or about January 25, 2021, the President of Crane\nemailed “onboarding profiles” for Investor-2, Investor-3, and Investor-4 to MSSB. As described\nabove, see ¶ 40(f), potential investors in the Investment Schemes were directed to send their\ninvestments to Crane, which purportedly served as payment processor for GTV, G Club, and/or\nHimalaya Exchange.\n3. On or about June 15, 2021, Investor-2 emailed a wire\ntransfer request to MSSB that stated the following, in substance and in part: “I’d like to invest [in]\n47\n\na company called Himalaya International Clearing Ltd.” The email requested a wire of\napproximately $3.4M to a Himalaya International Clearing Ltd. account at Metropolitan\nCommercial Bank. See infra ¶ 59(h).\nh. Based on my participation in this Investigation and my training and\nexperience, and as described above, I believe the approximately $5.1M in transfers from Investor-\n2 into Target Account-7 and the approximately $1 million in transfers from Investor-3 and\nInvestor-4 into Target Account-8 are the proceeds of wire fraud and money laundering, because\nthey are funds Investors-2 through-4 paid with the intent to purchase additional G Club\nmemberships and/or Himalaya Assets, but which GUO, JE and others instead directed into JE’s\nhedge fund bank account to conceal their true source and/or purpose. See, e.g., ¶ 56(b)(v).\ni. On or about June 11, 2021, JE opened Target Account-9 (i.e., a Silvergate\nBank account in the name of JE’s company, Hamilton Investment Management Ltd., ending in\n0288). Between at least in or about January 2022 and in or about June 2022, at least approximately\n$50.4 million of Investment Scheme Funds was transferred into Target Account-9 over the course\nof approximately five incoming wire transfers; specifically:\n1. On or about January 13, 2022, Target Account-9 received an\nincoming wire of approximately $10.8 million in Investment Scheme Funds from a Signature Bank\naccount in the name of Prime Trust, ending in 6126 (the “Prime Trust Signature Account”). See\n¶ 56(b)(i)-(iii).\n2. On or about February 10, 2022, Target Account-9 received an\nincoming wire of approximately $11.7 million in Investment Scheme Funds from the Prime Trust\nSignature Account.\n3. On or about June 13, 2022, Target Account-9 received an incoming\nwire of approximately $8 million in Investment Scheme Funds from a particular bank account at\n48\n\nMetropolitan Commercial Bank (“MCB”), ending in 6891 (the “6891 MCB Account”).\nTransaction details provided by Silvergate Bank list “FV Bank – Himalaya International” as the\nPayer on the transaction, and identify MCB as the name of the “Payer” financial institution. FV\nBank records, in turn, reflect that the transfer was from the 3763 FV Account, but do not reflect\nany involvement of MCB as an intermediary for the transaction. Based on information provided\nby MCB, I have learned that the 6891 MCB Account was a pooled funds account for FV Bank,\nand have further learned that MCB processes transactions for FV Bank’s account holders (as\nrelevant here, the Himalaya entities) in USD.\nj. On or about June 14, 2022, Target Account-9 received an incoming wire\nof approximately $10 million in Investment Scheme Funds from the 6891 MCB Account. FV\nBank account records reflect that the transfer was actually from the 3763 FV Account, but do not\nreflect any involvement of MCB as an intermediary for the transaction.\nk. On or about June 22, 2022, Target Account-9 received an incoming wire\nof approximately $10 million in Investment Scheme Funds from the 6891 MCB Account. FV\nBank account records reflect that the transfer was from the 3763 FV Account, but do not reflect\nany involvement of MCB as an intermediary for the transaction.\nFraud Proceeds are Used to Fund GUO-Affiliated Companies\n60. 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. As described above, JE’s company owns approximately 95% of Gettr. See\nsupra at ¶ 41(f).\n49\n\nb. On or about June 30, 2022, approximately $3 million was transferred from\nTarget Account-4 to Target Account-10 (i.e., a Manufacturers & Traders Trust Co. bank account\nheld in the name of GETTR USA, Inc., ending in 4409). The wire details reflect that the transfer\nwas for “CAPITAL CALL JUNE 3M USD.”\nc. On or about July 27, 2022, approximately $3 million was transferred from\nTarget Account-4 to Target Account-10. The wire details reflect that the transfer was for\n“CAPITAL CALL JULY 3M USD.”\nd. On or about August 29, 2022, approximately $5 million was transferred\nfrom Target Account-4 to Target Account-10. The wire details reflect that the transfer was for\n“CAPITAL CALL AUGUST 10M USD (X2 5M).”\ne. On or about August 30, 2022, an additional approximately $5 million was\ntransferred from Target Account-4 to Target Account-10. The wire details reflect that the\ntransfer was for “CAPITAL CALL AUGUST 5M USD (10M TRA NSFER 2 of 2).”\nf. Based on the foregoing, I believe that JE and others are using fraud proceeds\nto fund Gettr.\nFraud Proceeds are Layered Through Various Banking Institutions\n61. 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. As described herein, GUO, JE, and others have layered fraud proceeds\nthrough accounts at various entities, including, among others: certain accounts at MCB maintained\n50\n\nFBO FV Bank’s account holders (i.e., the Himalaya entities); and accounts held by BSI Group in\nthe name of various entities. See ¶ 56(b).\nb. As further described herein, FV Bank holds Investment Scheme Funds in\ncorrespondent bank accounts, or FBO accounts, at MCB.\n62. 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 that, starting at least in or about February 2022, JE and\nothers began to layer more than approximately $300 million in Investment Scheme Funds through\ncertain bank accounts. Specifically:\na. Between on or about February 15, 2022 and on or about March 29, 2022,\napproximately $160 million in Investment Scheme Funds was transferred from the 3763 FV\nAccount to a Royal Business Bank account in the name of Prime Trust LLC, ending in 6050 (the\n“Prime Trust RBB Account”) in the course of approximately 16 wire transactions.\nb. On or about March 21, 2022, JE opened an FV Bank account in the name\nof Himalaya International Financial Group, ending in 2119 (the “2119 FV Account”) and an FV\nBank account in the name of Himalaya International Reserves Ltd., ending in 8239 (the “8239 FV\nAccount”).\nc. Between on or about March 21, 2022 and on or about May 13, 2022,\napproximately $190 million in Investment Scheme Funds was transferred from the 3763 FV\nAccount (i.e., the Himalaya Clearing FV Bank account ending in 3763) to the 2119 FV Account\nand the 8239 FV Account in the course of approximately 12 wire transactions. For example:\n51\n\ni. Between on or about March 21, 2022 and on or March 29, 2022,\napproximately $100 million in Investment Scheme Funds was transferred from the 3763 FV\nAccount to the 2119 FV Account and/or the 8239 FV Account in the course of approximately 10\nwire transactions.\nii. On or about May 13, 2022, approximately $30 million in Investment\nScheme Funds was transferred from the 3763 FV Account to the 2119 FV Account in a single wire\ntransaction, and approximately $60 million in Investment Scheme Funds was transferred from the\n3763 FV Account to the 8239 FV Account in a single wire transaction.\nd. On or about May 24, 2022, approximately $44.6 million in Investment\nScheme Funds was transferred from the 2119 FV Account to the 8239 FV Account in a single wire\ntransaction.\ni. The approximately $44.6 million was part of approximately $80\nmillion that had been transferred from the 3763 FV Account to the 2119 FV Account. See\n¶ 62(c)(i)(ii).\nii. That is, while approximately $110 million was transferred directly\nfrom the 3763 FV Account to the 8239 FV Account, an additional approximately $44.6 million of\nthe approximately $190 million was transferred into the 8239 FV Account only after passing\nthrough the 2119 FV Account.\ne. On or about August 15, 2022, an employee of MCB sent email correspondence\nconfirming MCB’s relationship with FV Bank regarding Target Account-11, which is an MCB\naccount FBO FV Bank customers. The MCB employee confirmed that Target Account-11 is a\npooled account that contains funds for the Himalaya entities (i.e., the 3763 FV Account, the 2119\nFV Account, and the 8239 FV Account).\n52\n\n63. Based on my review of information provided by Silvergate, I have learned that\nTarget Account-1 through Target Account-9 held a combined total of approximately\n$292,407,029.22 as of on or about August 31, 2022, as reflected in the table below:\nTarget Account Account Number Balance\nTarget Account-1 5090037739 $1,800,000.00\nTarget Account-2 5090037705 $75,000,000.00\nTarget Account-3 5090037754 $467,343.00\nTarget Account-4 5090037713 $167,826.87\nTarget Account-5 5090042770 $83,872,761.75\nTarget Account-6 5090042762 $76,690,856.60\nTarget Account-7 5090042820 $5,106,100.00\nTarget Account-8 5090042747 $1,026,000.00\nTarget Account-9 5090030288 $48,276,141.00\nTotal $292,407,029.22\n64. Based on my review of information from Silvergate, I have learned that Target\nAccount-10 received a total of approximately $16,000,000.00 from Target Account-4 between\non or about June 30, 2022 and on or about August 30, 2022.\n65. Based on my review of information provided by FV Bank and MCB, I have learned\nthat Target Account-11 held a combined total of approximately $13,613,172.71 as of on or about\nAugust 15, 2022.\nIII. Conclusion\n66. Based on the foregoing, I submit that there is probable cause to believe that funds\nheld in the accounts constituting the Target Property are subject to forfeiture as proceeds of\nviolations of 18 U.S.C. § 1343 (wire fraud) and § 1344 (bank fraud), and/or as property involved\nin violations of 18 U.S.C. §§ 1956(a)(1)(B)(i), 1956(a)(2)(B)(i), and 1956(h) (money laundering\nand conspiracy to commit money laundering).\n53\n\n67. Accordingly, pursuant to 18 U.S.C. § 981(b), I respectfully request that the Court\nissue a warrant authorizing the seizure of the Target Property.\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\n54","body_zh":null,"key_entities":[],"ecf_references":[],"word_count":17290,"status":"published","published_at":"2025-07-28 00:00:00","created_at":"2025-07-28","updated_at":"2026-07-06 20:56:38"}