{"id":"court_sdny_716_6","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 F\n\nUNITED STATES DISTRICT COURT 23 MAG 3908\nSOUTHERN DISTRICT OF NEW YORK\nUNITED STATES OF AMERICA\nTO BE FILED UNDER SEAL\n-v.-\nAffidavit in Support of Seizure\nAll monies, funds, and assets contained in the Warrant\nTD Bank, N.A. official check account that were\npreviously held in TD Bank, N.A. accounts 440- Pursuant to 18 U.S.C. §§ 981 and 984\n5491468 and 440-5492044, held by G CLUB\nOPERATIONS LLC (the “Target Account”),\nand all funds traceable thereto, including\naccrued interest (the “Target Property”);\nDefendant-in-rem.\nSOUTHERN DISTRICT OF NEW YORK) ss.:\nZachary Effting, 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 February\n2020. Since in or about October 2020, I have been assigned to the FBI’s Complex Financial\nCrimes squad. During my time with the FBI, I have participated in investigations of securities and\nwire fraud schemes, bank fraud, and money laundering, and have, among other things, conducted\nor participated 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, property used in connection with crime, electronic devices, and other electronic\nevidence.\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, to seize the following\n\nproperty: all monies, funds, and assets contained in the TD Bank, N.A. official check account that\nwere previously held in TD Bank, N.A. accounts 440-5491468 and 440-5492044, held by G CLUB\nOPERATIONS LLC (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 review of\ndocuments and other evidence; (ii) my conversations with other law enforcement personnel and\nreview of law enforcement reports, including reports of surveillance; (iii) my review of publicly\navailable information, including digital videos posted on the Internet and other open source\nresearch conducted on the Internet relating to, among other ventures, “G|CLUBS”; (iv) my\nparticipation and the participation of other law enforcement officers in various witness interviews;\n(v)my review of evidence obtained pursuant to subpoenas, orders issued pursuant to 18 U.S.C.\n§2703(d) for non-content information, and judicially authorized search warrants, including\nemails, cellphone location data, and cellphone toll records; (vi) my review and analysis of various\nbank account records; and (vii) my training and experience concerning the commission of financial\ncrimes. Because this affidavit is being submitted for the limited purpose of establishing probable\ncause, it does not include all the facts that I have learned during the course of my investigation.\nWhere dates, figures, and calculations are set forth herein, they are approximate. Where the\ncontents of documents and the actions, statements, and conversations of others are reported herein,\nthey are reported in substance and in part, except where otherwise indicated.\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) and (C) and 18 U.S.C.\n§981(b) as property involved in violations of 18 U.S.C. § 1956 and § 1957, and/or the proceeds\n2\n\nof violations of 18 U.S.C. § 1343 , or property traceable thereto. In summary, the evidence reveals\na fraudulent scheme (the “Fraud”) that pertains to several interrelated companies and their\naffiliated entities, including GTV Media Group Inc., G Fashion (“G Fashion”), the Himalaya Farm\nAlliance (the “Farms”), Himalaya International Clearing Ltd. (“Himalaya International Clearing”),\nG Club Operations LLC (“G Club”), Hamilton Investment Management Ltd. (“Hamilton”), ACA\nCapital Group Ltd. (“ACA Capital”), and Crane Advisory Group LLC (“Crane”). As set forth in\nmore detail below, the leaders of the Fraud are Miles Guo, a/k/a “Guo Wengui,” a/k/a “Miles\nKwok” (“GUO”) and William Je, a/k/a Je Kin Ming (“JE”).\n6. Forensic accountants and analysts at the FBI and SEC and I have traced the flow of\ncertain fraud proceeds from victims of the fraud scheme to the purchase of 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)(2)(A) 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(A) with the intent to promote the carrying on or specified\nunlawful activity—\n[shall be guilty of a crime.]\n3\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. § 1957 provides that any person who knowingly engages or attempts to\nengage in a monetary transaction in criminally derived property of a value greater than $10,000\nand is derived from specified unlawful activity [shall be guilty of a crime.]\n12. 18 U.S.C. § 1956(h) further provides that “[a]ny person who conspires to commit\nany offense defined in [Sections 1956 and 1957] shall be subject to the same penalties as those\nprescribed for the offense the commission of which was the object of the conspiracy.”\nWire Fraud Offenses\n13. 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, as well as conspiracy\nto commit violations thereof. See 18 U.S.C. §§ 1956(c)(7) and 1961(1).\n14. Title 18, United States Code, Section 981(a)(1)(C), subjects to civil forfeiture any\nproperty, real or personal, which constitutes or is derived from proceeds traceable to a violation\nof . . . any offense constituting ‘specified unlawful activity’ (as defined in section 1956(c)(7) of\nthis title), or a conspiracy to commit such offense.”\n4\n\nSeizure Warrants\n15. The Court is empowered by 18 U.S.C. § 981(b) to issue a seizure warrant for any\nproperty subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A) & (C). Section 981(b)(2)\nprovides that such a seizure may be made “pursuant to a warrant obtained in the same manner as\nprovided for a search warrant under the Federal Rules of Criminal Procedure.” In addition, Section\n981(b)(3) provides that, notwithstanding the provisions of Federal Rule of Criminal Procedure\n41(a), a seizure warrant may be issued pursuant to Section 981(b) by a judicial officer in any\ndistrict in which a forfeiture action against the property may be filed under Title 28, United States\nCode, Section 1355(b). Under Section 1355(b)(1)(A), a forfeiture action or proceeding may be\nbrought in the district in which any of the acts or omissions giving rise to the forfeiture occurred.\nAs set forth below, the offenses underlying the requested seizure warrant included acts or\nomissions occurring in the Southern District of New York.\nIII. Probable Cause\nA. Background\nIndictments\n16. On March 30, 2023, the Government filed a 12-count superseding Indictment,\ncaptioned United States v. Ho Wan Kwok, Kin Ming Je, and Yanping Wang, S1 23 Cr. 118 (the\n“Indictment”), charging Ho Wan Kwok, a/k/a “Miles Guo,” a/k/a “Miles Kwok,” a/k/a “Guo\nWengui,” a/k/a “Brother Seven,” a/k/a “The Principal” (“KWOK”), Kin Ming Je, a/k/a “William\nJe” (“JE”), and Yanping Wang, a/k/a “Yvette” (“WANG”) with violations of 18 U.S.C. §§ 371\n(conspiracy to commit wire, bank and securities fraud and money laundering), 1343 (wire fraud),\n1957 (unlawful monetary transactions), and 2 (aiding and abetting). The Indictment also charged\nKWOK and JE with violations of 18 U.S.C. §§ 1956(a)(2)(A) (international concealment money\nlaundering) and 1956(a)(2)(B)(i) (international promotional money laundering); and 15 U.S.C.\n5\n\n§§ 78j(b) & 78ff and 17 C.F.R. § 240.10b-5 (securities fraud). In addition, the Indictment charged\nJE with a violation of 18 U.S.C. § 1512(c)(2) (obstruction of justice). The Indictment is attached\nhereto as Exhibit 1 and is incorporated by reference herein.\nOverview of the Investigation\n17. 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 fraud (the “Fraud”) that pertains to several companies that are owned or operated\nby, or otherwise affiliated with, KWOK, JE, WANG, and other Target Subjects. To date, the\ninvestigation has revealed that the Fraud involved the solicitation of more than $1 billion and the\nsubsequent money laundering and/or misappropriation of hundreds of millions of dollars. KWOK\nis the leader of, and directed, the Fraud. JE is the financial architect and key money launderer for\nthe Fraud. WANG operated as KWOK’s “chief of staff” and managed the day-to-day operations\nof the entities used to perpetrate the Fraud.\n18. KWOK, JE, and WANG have conducted the Fraud, which occurred between at\nleast in or about 2018 through in or about March 2023, through various interrelated offerings, all\nof which exhibit features that are consistent with fraud. For example, as described further below\nand in the Indictment, investors were promised unrealistic, outsized returns on their investments;\ninvestors were induced to invest on the basis of numerous misrepresentations; a large portion of\nthe investment money was misappropriated; and with respect to the sale of digital asset securities,\nthose currencies have never been tradable on a public exchange, despite representations that they\nwould be.\n19. Based on my conversations with other law enforcement officers who have\nparticipated in this investigation and my review of the Indictment, I have learned that the Fraud\nincludes, among other means and methods, the following:\n6\n\na. Starting at least in or about June 2020, KWOK began promoting G|CLUBS,\na purported high-end membership club. G|CLUBS, which launched in or about October 2020,\nclaimed to provide “Membership Concierge services with exclusive offers and discounts for luxury\nhotels and retailers for High Net Worth individuals from the Asian market” through the sale of\npurported memberships. In soliciting G|CLUBS membership funds, KWOK and others\nrepresented that G|CLUBS membership would be a mechanism to obtain stock in KWOK-\naffiliated companies, including GTV and a company called G|FASHION. G|CLUBS raised at\nleast approximately $250 million in purported membership fees, which funds were commingled\nwith other fraud proceeds and used to promote the Fraud and/or misappropriated. See Ex. 1 at\n¶¶ 14-15.\n20. Based on my training and experience and my conversations with other law\nenforcement officers who have participated in this investigation, I am aware that each of these\nmeans and methods of the Fraud described more fully in the Indictment bear the hallmarks of\nfraud. For example, the investors were promised unrealistic outsized returns on their investments;\ninvestors were induced to invest on the basis of numerous misrepresentations; and more than\napproximately $300 million in fraud proceeds has been misappropriated, including an\napproximately $100 million investment in a high-risk hedge fund for the benefit of KWOK’s son,\nthe purchase of a mansion in Mahwah, New Jersey for approximately $26.5 million in or about\nDecember 2021 through an entity owned and controlled by JE on behalf of KWOK, and the\ntransfer of approximately $13 million in fraud proceeds to an escrow account, which funds were\nsubsequently used to pay for extravagant renovations to, and furnishings for, the Mahwah\nMansion. See Ex. 1 at ¶¶ 12(h), 13(f), 15.\n7\n\nFinancial Investigation of Fraud Proceeds\n21. Based on my conversations with other law enforcement officers and my training\nand experience, I am aware that financial tracing analysis conducted by the United States\nAttorney’s Office for the Southern District of New York (USAO-SDNY), the FBI, and the SEC\n(which is engaged in a parallel investigation) uncovered extensive layering of Fraud funds through\nmore than 500 accounts at financial institutions, held in the names of more than 80 individuals or\nentities, including various of the KWOK-controlled entities and dozens of other affiliated entities\nthat KWOK, JE, WANG, and other Target Subjects appear to have established as money\nlaundering vehicles. As the examples described in part in paragraphs 22-24, infra, show, financial\ntracing identified large transfers of Fraud proceeds to, through, and among domestic and\ninternational bank accounts, including accounts that JE controlled in the UAE and the Bahamas,\nconsistent with a large-scale layering of proceeds of crime for purposes of concealing their source,\norigin, location, and/or nature. See, e.g. Ex. 1 at ¶¶ 3, 4, 32, 32(g).\nTracing of Fraud Scheme Proceeds\n22. 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 participated in the Fraud by either wiring money directly to a bank\naccount controlled or used by entities affiliated with KWOK, JE, and others (including the Farms,\nG|CLUBS, or the Himalaya Exchange), or by wiring or otherwise transferring money to other\nentities at the direction of the Target Subjects (including, for example, a company called Crane\nAdvisory Group (“Crane”), which funds are then transmitted to bank accounts ultimately\n8\n\ncontrolled by KWOK, JE, and their associates). I am aware of accounts located in the UAE, the\nUnited Kingdom, the United States, the Bahamas, and the British Virgin Islands, which KWOK,\nJE, and other Target Subjects have used for the purpose of receiving investment funds from\ninvestors in the Fraud, including G|CLUBS investors.\nb. For example, between in or about May 2021 and June 2021, approximately\n$100 million in Fraud funds were transferred from G|CLUBS bank accounts into a Bahamas bank\naccount held in the name of Hamilton Capital Management Ltd. (the “Hamilton Bahamas\nAccount”), which is a JE-controlled company. Before the approximately $100 million of Fraud\nfunds was combined in the Hamilton Bahamas Account, they were layered through a series of\nentities at various different banks in a manner that, based on my training and experience, is\nindicative of money laundering. Specifically:\ni. Certain prospective investors were instructed to send funds intended\nas an investment in GTV (for example) to bank accounts in the name of Crane. Approximately\n$78.2 million of Fraud funds was sent from individual or institutional investors in China and\nelsewhere to two Crane bank accounts (the “Crane Citibank Accounts”) between in or about\nNovember 2020 and April 2021.\nii. Approximately $60 million of those Fraud funds were then\ntransferred from the Crane Citibank Accounts to approximately five different bank accounts at\nMorgan Stanley Smith Barney (“MSSB”) held in the name of Crane (together, the “Crane MSSB\nAccounts”).\niii. The approximately $60 million in Fraud funds from the Crane\nMSSB Accounts was combined with approximately $49 million in other Fraud funds that had been\ntransferred into the Crane MSSB Accounts from two Crane accounts at a different bank, Capital\n9\n\nOne (together, the “Crane Capital One Accounts”), raising the total combined balance in the Crane\nMSSB Accounts to approximately $109 million.\niv. Approximately $79 million of those approximately $109 million in\nFraud funds in the Crane MSSB Accounts were then transferred to accounts at the same bank (i.e.,\nMSSB), but in the name of G|CLUBS (i.e., the G|CLUBS MSSB Accounts). The approximately\n$79 million was combined with approximately $79.7 million in other Fraud funds that had been\ntransferred into the G|CLUBS MSSB Accounts from individual G|CLUBS investors and from\nG|CLUBS bank accounts at Signature Bank, First Bank of Puerto Rico, and City National Bank,\nraising the total combined balance of Fraud funds in the G|CLUBS MSSB Accounts to more than\napproximately $158 million.\nv. Between in and about October 2021 and in or about April 2022,\napproximately $85 million of Fraud funds was transferred from the G|CLUBS MSSB Accounts to\nthe Hamilton Bahamas Account, and combined with approximately $15 million in other Fraud\nfunds (relating to G|CLUBS and the Himalaya Exchange). Thus, the $100 million of Fraud funds\nin the Hamilton Bahamas Account consisted exclusively of funds transferred from the G|CLUBS\nMSSB Accounts and other accounts containing Fraud funds.\n23. Between in or about September 2022 and March 2023, law enforcement served\njudicially authorized seizure warrants on several U.S. banks for the funds located in approximately\n21 additional bank accounts, into which I and forensic accountants and analysts at the FBI and\nSEC traced proceeds of the Fraud. The bank accounts subject to seizure were held in the names\nof various entities associated with KWOK and JE, or entities under JE’s control, including\nG|CLUBS, G|Fashion, and the Hamilton entities that control the Himalaya Exchange. Between in\nor about September 2022 and March 2023, the Government seized approximately $630 million in\nfraud proceeds pursuant to the seizure warrants, including approximately $11,538,579.87 from a\n10\n\nG|CLUBS account at Mercantile Bank (the “G|CLUBS Mercantile Account”), which represented\nthe balance in the account at the time of seizure. See Ex. 1 at ¶¶ 23-24.\n24. Based on my participation in this investigation, training, experience, review and\nanalysis of various bank account records and financial analyses performed by me and forensic\naccountants and analysts at the FBI and SEC, my review of court filings and evidence obtained\npursuant to subpoenas and judicially authorized search warrants, and my conversations with\nothers, I have learned the following, among other things:\na. On or about May 5, 2021, a business bank account application was\nsubmitted to Mercantile Bank for the G|CLUBS Mercantile Account. The application for the\nG|CLUBS Mercantile Account described G|CLUBS’s business as, in substance and in part,\n“holding the securities of (or other equity interests in) companies and enterprises.”\nb. Alex Hadjicharalambous, the Financial Controller for G|CLUBS, was an\nauthorized signer on the G|CLUBS Mercantile Account.\nc. Proceeds of the Fraud were traced into G|CLUBS Mercantile Account. For\nexample:\ni. The initial deposit of funds into G|CLUBS Mercantile Account,\nwhich occurred on or about July 2, 2021, consisted of an approximately $4 million transfer of\ntraceable Fraud proceeds from a G|CLUBS account held at Medici Bank.\nii. Between on or about August 23, 2021 and November 19, 2021,\napproximately $74 million of Fraud proceeds was transferred from the G|CLUBS MSSB Accounts\ninto the G|CLUBS Mercantile Account.\niii. On or about December 24, 2021, approximately $10 million of\nFraud proceeds was transferred from a Silvergate Bank account ending in -7739, held in the name\n11\n\nof Hamilton Opportunity Fund SPC (which account was seized pursuant to one of the\nGovernment’s prior seizure warrants) to the G|CLUBS Mercantile Account.\nThe Target Property\n25. Based on my review of documents, subpoena and search warrant returns, law\nenforcement reports, my conversations with witnesses and other law enforcement officers, and my\ntraining and experience, I am aware of the following, among other things:\na. Subpoena returns provided by TD Bank, N.A. reflect that “G Club\nOperations LLC” opened two bank accounts at TD Bank on or about January 13, 2022—\nspecifically, a business premier checking account ending in -1468 (the “1468 Account”) and a\nbusiness simple checking account ending in -2044 (the “2044 Account,” and together with the\n1468 Account, the “TD Accounts”).\nb. In account opening documentation dated on or about January 13, 2022,\nLimarie Reyes Molinaris (“Reyes Molinaris”), the then-CEO for G|CLUBS, is listed as the sole\nauthorized signer for the TD Accounts. On or about February 1, 2022, the signature card for each\nof the TD Accounts was updated to add Alex Hadjicharalambous, the Financial Controller for\nG|CLUBS, as an additional authorized signer. See supra at ¶ 24(b).\nc. On or about January 14, 2022, Reyes Molinaris deposited a “Manager’s\nCheck” from Oriental Bank in Puerto Rico into the 1468 Account; the check was in the amount of\napproximately $2,931,953.17, was dated November 22, 2021, was made payable to G CLUB\nOPERATIONS LLC. Based on my participation in this investigation and my review of\ndocuments, I am aware that the Oriental Bank check represented the balance of a G|CLUBS\naccount that Oriental Bank had closed, which account held funds traceable to the Fraud, that is,\nfunds derived from the fraudulent solicitation of investments. Based on my review of records for\nthe 1468 Account, I am aware that only approximately 21 disbursements were made from the 1468\n12\n\nAccount, and I am further aware that those disbursements consisted primarily of wire / ACH fees\nand check card purchases amounting to less than approximately $128,000 in debits.\nd. On or about January 14, 2022, approximately 13 checks were deposited into\nthe 2044 Account, for a collective deposit of approximately $313,600.00. The 13 checks were\nmade payable to G CLUB OPERATIONS LLC and were dated between on or about July 15, 2021\nand on or about August 3, 2021. Based on my review of documents, including G|CLUBS\nmembership lists and the memo lines of the checks, it appears that the checks were from G|CLUBS\ninvestors who were fraudulently induced to invest money. Between in or about January 2022 and\nJuly 2022, the 2044 Account received approximately $15,707,658.67 in credits (consisting of\ndeposits from G|CLUBS investors who were fraudulently induced to invest money) and\napproximately $9,637,000.17 in debits (including two outgoing wires to a particular bank account\nat Kyrgyz-Swiss Bank in Kyrgyzstan totaling approximately $7,000,000).\ne. TD Bank closed the TD Accounts on or about March 7, 2023.\ni. The 1468 Account statement for the period March 1, 2023 through\nMarch 7, 2023 reflects a closing balance of approximately $2,815,502.30. On or about March 7,\n2023, TD Bank issued a check to G CLUB OPERATIONS LCC (numbered 90519810-6) for the\nclosing balance of the 1468 Account.\nii. The 2044 Account statement for the period March 1, 2023 through\nMarch 7, 2023 reflects a closing balance of approximately $4,357,924.95. On or about March 7,\n2023, TD Bank issued a check to G CLUB OPERATIONS LCC (numbered 90519811-7) for the\nclosing balance of the 2044 Account.\nf. Based on my participation in this investigation, my review of documents,\nand my conversations with others, I am aware that the combined approximately $7,173,427.25 that\nrepresents the closing balances of the TD Accounts is currently being held in the Target Account\n13\n\n(i.e., the TD Bank, N.A. official check account that is holding funds previously held in TD Bank,\nN.A. accounts 440-5491468 and 440-5492044, held by G CLUB OPERATIONS LLC).\nIV. Conclusion\n26. Based on the foregoing, I submit that there is probable cause to believe that the\nfunds held in the Target Property are subject to forfeiture as proceeds of violations of 18 U.S.C.\n§1343 (wire fraud), and/or as property involved in violations of 18 U.S.C. §§ 1956(a)(2)(A)(i),\n1956(a)(2)(B)(i), 1957, and 1956(h) (money laundering and conspiracy to commit money\nlaundering).\n27. 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_Z_a_c_h_a_r_y_ _E_ff_t_in_g_ _(b__y_ V_F__ w__it_h_ p_e__rm__is_s_i_o_n_)__\nZACHARY EFFTING\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\n_1_2 day of May, 2023\n_____________________________________\nTHE HONORABLE VALERIE FIGUEREDO\nUNITED STATES MAGISTRATE JUDGE\nSOUTHERN DISTRICT OF NEW YORK\n14\n\nEx. 1\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g1e o 1f 74 0of 56\nUNITED STATES DISTRICT COURT ORIGINAL 1\nSOUTHERN DISTRICT OF NEW YORK\nUNITED STATES OF AMERICA INDICTMENT\nV. Sl 23 Cr. 118 (AT)\nHO WAN KWOK,\na/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\"\na/k/a \"The Principal,\"\nKINMINGJE,\na/k/a \"William Je,\" and\nYANPING WANG,\na/k/a \"Yvette,\"\nDefendants.\nCOUNT ONE\n(Conspiracy to Commit Wire Fraud, Securities Fraud, Bank Fraud, and\nMoney Laundering)\nThe Grand Jury charges:\nOverview\n1. From at least in or about 2018 through at least in or about March 2023, HO WAN\nKWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\"\na/k/a \"The Principal,\" KIN MING JE, a/k/a \"William Je,\" and Y ANPING WANG, a/k/a \"Yvette,\"\nthe defendants, and others known and unknown, conspired to defraud thousands of victims of more\nthan approximately $1 billion, including victims located in the Southern District of New York.\nKWOK, JE, WANG, and their co-conspirators operated through a series of complex fraudulent\nand fictitious businesses and investment opportunities that connected dozens of interrelated\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g2e o 1f 84 0of 56\nentities, which allowed the defendants and their co-conspirators to solicit, launder, and\nmisappropriate victim funds.\n2. HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\" a/k/a \"The Principal,\" KIN MING JE, a/k/a \"William Je,\" and YANPING\nWANG, a/k/a \"Yvette,\" the defendants, and their co-conspirators, took advantage of KWOK's\nprolific online presence and hundreds of thousands of online followers to solicit investments in\nvarious entities and programs by promising outsized financial returns and other benefits. The\nentities and programs used in the scheme included those known as GTV, GICLUBS, GIMUSIC,\nGIFashion, and the Himalaya Exchange, among others. In truth and in fact, and as KWOK, JE,\nand WANG well knew, the entities were instrumentalities that KWOK, JE, and WANG created\nand used to perpetrate their fraud and exploit KWOK's followers. The scheme allowed KWOK,\nJE, and WANG to enrich themselves, their family members, and their co-conspirators, and to fund\nKWOK's extravagant lifestyle.\n3. As part of the scheme, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" KIN MING JE, a/k/a \"William\nJe,\" and YANPING WANG, a/k/a \"Yvette,\" the defendants, and their co-conspirators, laundered\nhundreds of millions of dollars of fraud proceeds. To conceal the illegal source of the funds,\nKWOK, JE, and WANG transferred, and directed the transfer of, money into and through more\nthan approximately 500 accounts held in the names of at least 80 different entities or individuals.\nHundreds of millions of dollars of the fraudulent scheme's proceeds were transferred, either\ndirectly or indirectly, to bank accounts in the United States, Bahamas, and United Arab Emirates\n(\"UAE\"), among other places, and held in the name of companies owned or otherwise controlled\nby JE.\n2\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g3e o 1f 94 0of 56\n'v\n4. HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the\ndefendants, used more than approximately $300 million of the fraudulent scheme's proceeds for\ntheir and their families' benefit. For example, KWOK used fraudulently-obtained victim money\nto purchase, fund, or finance a $26.5 million purchase of an approximately 50,000-square-foot\nmansion in New Jersey for KWOK and his family; luxury vehicles, including an approximately\n$3.5 million Ferrari for one ofKWOK's close family members (\"Relative-I\"); an approximately\n$37 million luxury yacht that was used by KWOK and his family and purchased in the name of\none ofKWOK's close family members (\"Relative-2\"); a piano valued at approximately $140,000;\nan approximately $36,000 mattress; and a $100 million investment in a high-risk hedge fund for\nthe ultimate benefit of Relative-I, among other things. For his part, among other things, JE\ntransferred at least $10 million of the fraud proceeds into his and his spouse's personal bank\naccounts.\n5. HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\" a/k/a \"The Principal,\" KIN MING JE, a/k/a \"William Je,\" and YA NPING\nWANG, a/k/a \"Yvette,\" the defendants, and their co-conspirators, operated the scheme for years,\nand continued to do so at least through at least March 2023. They did so, among other things, by\ncontinually adapting the scheme's means and methods to evade the enforcement of investor\nprotection, anti-money laundering, and bankruptcy laws in the United States, and by retaliating\nagainst individual victims who complained or demanded the return of invested funds.\n3\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g4e o 2f 04 0of 56\nRelevant Persons and Entities\n6. At all relevant times, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant, was the leader\nof, and directed, the scheme.\na. KWOK is an exiled Chinese businessman who fled to the United States in\nor about 2015 and purchased a penthouse apartment at a New York City hotel for approximately\n$67.5 million. Starting at least in or about 2017, KWOK, who then purported to be a billionaire,\ngarnered a substantial online following. KWOK granted numerous media interviews and posted\non social media, claiming to advance a movement against the Chinese Communist Party.\nb. In or about 2018, KWOK founded two purported nonprofit organizations,\nnamely, the Rule of Law Foundation and the Rule of Law Society. The Rule of Law Society's\nwebsite lists KWOK as its \"founder, a promot[e]r, and a spokesperson.\" Both organizations\nfeature photographs of KWOK on their websites. KWOK used the nonprofit organizations to\namass followers who were aligned with his purported campaign against the Chinese Communist\nParty and who were also inclined to believe KWOK's statements regarding investment and money\nmaking opportunities. In truth and in fact, and as KWOK well knew, he and others provided false\nand materially misleading information to promote these \"opportunities\" and to defraud KWOK's\nfollowers and other victims.\n7. At all relevant times, KIN MING JE, a/k/a \"William Je,\" the defendant, was a dual\ncitizen of Hong Kong and the United Kingdom who principally resided in the United Kingdom,\nwhile traveling to the United States and elsewhere. JE owned and operated numerous companies\nand investment vehicles central to the scheme and served as its financial architect and key money\nlaunderer.\n4\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g5e o 2f 14 0of 56\n8. At all relevant times, Y ANPING WANG, a/k/a \"Yvette,\" the defendant, was a\ncitizen of China who principally resided in New York, New York and has had a close relationship\nwith HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a\n\"Brother Seven,\" a/k/a \"The Principal,\" the defendant. In particular, WANG has worked for\nKWOK and KWOK's family for several years, since at least in or about 2018, and has operated as\na \"chief of staff' for KWOK. In that capacity, WANG has held titles in a variety of entities that\nwere instrumentalities of the fraud described herein. For example, WANG has served as the\nPresident, Treasurer, and Secretary of entities that purportedly managed KWOK's money.\n9. At certain times relevant to this Indictment, Saraca Media Group, Inc. (\"Saraca\")\nwas a corporation based in New York, New York. Relative-I was its ultimate beneficial owner.\n10. At certain times relevant to this Indictment, GTV Media Group, Inc. (\"GTV\") was\na purported news-focused social media platform based in New York, New York. GTV was\nfunctionally owned and controlled by HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant, although\nKWOK held no formal position or title at GTV. KIN MING JE, a/k/a \"William Je,\" the defendant,\nlikewise held no formal position or title at GTV, but in fact exercised control over its finances.\nSaraca was the parent company of GTV. YANPING WANG, a/k/a \"Yvette,\" the defendant, was\nan \"Executive Director\" of GTV.\n11. At certain times relevant to this Indictment, G Club Operations, LLC (\"GICLUBS\")\n_was a purported membership organization based in Puerto Rico and in New York, New York.\nGICLUBS was functionally owned and controlled by HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant,\nalthough KWOK held no formal position or title at GICLUBS. KIN MING JE, a/k/a \"William Je,\"\n5\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g6e o 2f 24 0of 56\nthe defendant, likewise held no formal position or title at GICLUBS, but in fact exercised control\nover its finances. .\n12. At certain times relevant to this Indictment, the \"Himalaya Exchange\" was a\npurported cryptocurrency \"ecosystem\" that KIN MING JE, a/k/a \"William Je,\" the defendant,\nfounded and operated through various entities he owned, which were based abroad. Entities\nfunctionally owned and controlled by HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant, such as\nGICLUBS and GIFashion, had purported business relationships with the Himalaya Exchange.\nKWOK promoted the Himalaya Exchange and claimed to be the designer of its purported\ncryptocurrency, although KWOK held no formal position or title at the Himalaya Exchange.\nThe Fraud\nThe GTV Private Placement\n13. Between in or about April 2020 and in or about June 2020, HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" KIN MING JE, a/k/a \"William Je,\" and YA NPING WANG, a/k/a \"Yvette,\" the\ndefendants, and others known and unknown, fraudulently obtained more than $400 million in\nvictim funds through an illegal private stock offering related to GTV (the \"GTV Private\nPlacement\").\na. On or about April 21, 2020, KWOK posted, and caused to be posted, a video\non social media announcing the unregistered offering of GTV common stock via a private\nplacement. In that video, KWOK described, in substance and in part, the investment terms for the\nGTV Private Placement, and directed people to contact him, via a mobile messaging application,\nwith any questions about the GTV Private Placement. The video and GTV Private Placement\n6\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g7e o 2f 34 0of 56\nmaterials-including the written \"Confidential Information Memorandum\" (the \"PPM\"),\nSubscription Agreement, and Investment Procedure Guidelines-were transmitted to thousands of\npotential investors, including those in the Southern District of New York, via mobile messaging\napplications, social media, and text messages.\nb. The PPM promoted GTV as the \"first ever platform which will combine the\npower of citizen journalism and social news with state-of-the-'art technology, big data, artificial\nintelligence, block-chain technology and real-time interactive communication.\"\nc. According to the PPM' s metadata, JE was the \"author\" of the PPM. The\nPPM disclosed the terms of the GTV Private Placement and identified KWOK as GTV's \"Sponsor\nand Adviser.\" According to the PPM, among other GTV materials, neither KWOK nor JE held\nany formal management position with GTV. Y ANPING WANG, a/k/a \"Yvette,\" the defendant,\nwas identified in the PPM as an \"Executive Director\" of GTV.\nd. The PPM also contained the following representations, in substance and in\npart, among others:\nThe GTV Private Placement was for investors who were \"interested\n1.\nin evaluating an opportunity to invest capital into GTV;\"\nii. GTV planned to use the proceeds raised from the GTV Private\nPlacement \"to expand and strengthen the business;\" and\nThe PPM included a chart itemizing the \"contemplated use of\n111.\nproceeds\" raised from the GTV Private Placement:\n7\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g8e o 2f 44 0of 56\nAcquisition of companies to strengthen and grow\nGTV\nUpgrade of GTV technology and security Approximate 10%\nMarketing Approximate 8%\nWorking capital Approximate 7%\nOther Approximate 5%\nTotal 100%\ne. Between on or about April 20, 2020 and on or about June 2, 2020,\napproximately $452 million worth ofGTV common stock was purportedly sold to more than 5,500\ninvestors located in the United States, including in the Southern District of New York, and abroad.\nInvestors participated in the GTV Private Placement based, in part, on the belief that their money\nwould be invested into GTV to develop and grow that business, as the PPM promised.\nf. The vast majority of the proceeds derived from investors in the GTV Private\nPlacement were not used to develop and grow the GTV business, but instead were deposited\ndirectly into bank accounts held in the name of Saraca, GTV's parent company, which is\nbeneficially owned by Relative-I.\ng. The GTV Private Placement was not made pursuant to a registration\nstatement filed with the U.S. Securities and Exchange Commission (\"SEC\"). Rather, the offering\nwas purportedly made pursuant to SEC regulations that permit the sale of unregistered securities\nsubject to limitations on the type of investors to whom the securities are offered and the manner in\nwhich their investments may be solicited. To evade these limitations, however, KWOK, and others\n8\n\nCaseC a1s:2e3 1-c:2r-30-0c1r-1080-1A1T8 - A TD o Dcuomcuemnte 7n1t 61-96 F iFleilde d0 30/72/92/82/32 5 P a gPea g9e o 2f 54 0of 56\nunder his control, used at least one intermediary entity to purchase GTV stock on behalf of pools\nof investors who did not qualify to participate in the GTV Private Placement.\nh. In or about early June 2020, and only days after the GTV Private Placement\nclosed, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a\n\"Brother Seven,\" a/k/a \"The Principal,\" KIN MING JE, a/k/a \"William Je,\" and YANPING\nWANG, a/k/a \"Yvette,\" the defendants, and their co-conspirators, misappropriated approximately\n$100 million raised from investors in the GTV Private Placement and directed that those funds be\nplaced with a high-risk hedge fund (\"Fund-I\") for the benefit of Saraca and its ultimate beneficial\nowner, Relative-I. This transaction was contrary to the PPM's representations to prospective GTV\ninvestors about how investments in GTV would be used. Indeed, the $100 million investment into\nFund-I was not made for the benefit of GTV, but rather for the benefit of Saraca. The victims\nwho supplied the $100 million invested into Fund-I did not own any shares of Saraca. Ultimately,\nthe investment into Fund-I lost approximately $30 million in value.\ni. After directing $100 million of GTV victim funds into Fund-I, HO WAN\nKWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\"\na/k/a \"The Principal,\" the defendant, continued to promote GTV using false and misleading\nrepresentations.\nThe Farm Loan Program\n14. Beginning in or about June 2020-the same month that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and their co-conspirators\nmisappropriated money from the GTV Private Placement for the benefit of Saraca and\nRelative-I-KWOK, JE, and their co-conspirators fraudulently obtained more than approximately\n9\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g0e o2f6 4 o0f 56\n$150 million in victim funds through the \"Himalaya Farm Alliance.\" The Himalaya Farm\nAlliance, which KWOK organized and promoted, was a collective of informal groups (e ach known\nas a \"Farm\") located in various cities around the world. KWOK, JE, and others working on their\nbehalf and at their direction, obtained these funds by making further misrepresentations to the\ninvestors in the GTV Private Placement and fraudulently soliciting further investments, this time\nin the form of \"loans\" to a Farm, and promising that such loans would be convertible into GTV\ncommon stock at a conversion rate of one share per dollar loaned (the \"Farm Loan Program\").\na. Starting in or about June 2020, domestic banks that held accounts used to\nprocess the funds raised through the GTV Private Placement began to freeze and close GTV\nassociated bank accounts because, among other reasons, the accounts had received dozens of large\nincoming wire transfers, some of which referenced an unregistered stock offering.\nb. These bank account closures frustrated the ability of KWOK, JE, and their\nco-conspirators to collect proceeds from victims seeking to invest in GTV.\nc. On or about July 22, 2020, in a video distributed via social media, KWOK\npromoted the Farm Loan Program. According to KWOK and those working on his behalf,\nindividuals seeking to invest (or reinvest) in GTV could participate in the Farm Loan Program.\nd. After launching the Farm Loan Program, KWOK continued to promote\nGTV and to falsely represent the value of GTV. For example, on or about August 2, 2020, in a\nvideo distributed via social media, KWOK falsely stated, in substance and part, \"How much is\nGTV? .. . a market value of2 billion US dollars.\"1 In truth and in fact, and as KWOK well knew,\nGTV's market value was far less because, among other things, GTV was a new business that\ngenerated no revenue.\n1 All statements attributed herein to KWOK have been translated from Mandarin to English,\nunless otherwise noted.\n10\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g1e o2f7 4 o0f 56\ne. Thousands of victims \"loaned\" money to the Farms by sending money to\nbank accounts controlled by the Farms (and not GTV). According to the \"Loan Agreements,\"\nwhich the Farms frequently did not countersign, these funds were to be used for a Farm's \"general\nworking capital purposes.\"\nf. KWOK and JE misappropriated funds that were raised through the Farm\nLoan Program. For example:\ni. Approximately $20 million was transferred to Relative-I,\napproximately $950,000 of which was used to pay for flight crew services on a private jet;\nii. Approximately $5 million was transferred to an entity owned by\nKWOK's spouse;\niii. Approximately $2.3 million was used to cover maintenance\nexpenses associated with an approximately 145-foot luxury yacht worth approximately $37\nmillion, nominally owned by Relative-2 and used by KWOK; and\niv. Approximately $10 million was transferred to personal bank\naccounts in the name of JE and/or JE's spouse.\nGICLUBS\n15. While making misrepresentations regarding the Farm Loan Program, HO WAN\nKWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\"\na/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others known\nand unknown, fraudulently induced KWOK's followers to transfer additional funds to a purported\nonline membership club called GICLUBS. From at least in or about October 2020 through at least\n11\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g2e o2f8 4 o0f 56\nin or about March 2023, KWOK, JE, and others known and unknown, fraudulently obtained more\nthan approximately $250 million in victim funds through GICLUBS.\na. Starting at least on or about June 20, 2020, in a video distributed via social\nmedia, KWOK promoted and encouraged individuals to purchase what KWOK referred to as a\n\"G Club . . . membership card.\"\nb. Formally launched in or about October 2020, GICLUBS claimed, on its\nwebsite, to be \"an exclusive, high-end membership program offering a full spectrum of services\"\nand \"a gateway to carefully curated world-class products, services and experiences.\"\nc. To join GICLUBS, a member was required to make a one-time payment to\npurchase a \"membership,\" in addition to an annual membership fee. The cost of the membership\nvaried based on the membership tier selected by the prospective member: Tier 5 Membership cost\n$50,000; Tier 4 Membership cost $40,000; Tier 3 Membership cost $30,000; Tier 2 Membership\ncost $20,000; and Tier 1 Membership cost $10,000.\nd. On or about July 5, 2021, in a video distributed via social media, KWOK\nstated, in substance and in part, that there were \"25,000 [GICLUBS] member[s] ... $100 million\ndollars, the cash [in] the bank account. Then we have the 111 million ... [who] want to join.\" By\ncontrast, GICLUBS internal documents reflected approximately 5,900 active members as of in or\nabout August 2021.\ne. In truth and in fact, and as KWOK and JE well knew, GICLUBS provided\nnothing close to \"a full spectrum of services\" and \"experiences\" to its members. Despite collecting\nhundreds of millions of dollars in purported membership fees, GICLUBS maintained a relatively\nsmall number of employees and provided its members few to no discemable membership benefits.\nIndeed, GICLUBS did not even make good on prizes it offered members for participating in\n12\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g3e o2f9 4 o0f 56\ncontests. On or about February 14, 2021, GICLUBS held a webcast and sweepstakes during which\nmembers were promised luxury prizes. On at least one occasion, instead of providing a BMW to\na member who purportedly won a sweepstakes, GI CLUBS claimed to the member that the member\nhad requested that the value of the BMW be applied toward an upgrade from a Tier 1 GICLUBS\nMembership to a Tier 4 GICLUBS Membership and partially credited toward annual membership\nfees for the next three years. As of on or about March 8, 2021-months after GICLUBS launched\nand began to collect \"membership\" fees-GICLUBS did not have a business plan or a board of\ndirectors.\nf. KWOK and JE also used GICLUBS as a mechanism to continue fraudulent\nprivate placement offerings. KWOK, and others known and unknown, told KWOK's online\nfollowers that their purchase of GICLUBS memberships would entitle them to stock in KWOK\naffiliated entities, such as GTV and GIFashion.\ni. In a conversation regarding GICLUBS membership funds on or\nabout May 4, 2021, JE stated, in substance and in part, that \"first of all, [prospective members] are\nbuying the GICLUBS membership, but they are expecting they would probably receive some\nshares, you know, on, on, on the future GTV, I think this is their expectation.\"\nii. On or about July 30, 2021, KWOK stated in a video distributed via\nsocial media, in substance and in part, \"Some of the comrades in arms asked, ' [w ]ill I still get a\nfree stock offer when I buy a GICLUBS membership?' 100%. Because I said that I have to promise\nthat anyone who buys G-Club membership before September 17 must be allotted shares, which is\nexactly the same. Because we said that anyone can choose whether to use your money to buy G\nClub before September 17, G-Club and the stock shares. You'll get both.\"\n13\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g4e o3f0 4 o0f 56\ng. KWOK, JE, and others known and unknown, asked investors to purchase\nmultiple memberships in GICLUBS, enabling KWOK and JE to increase the amount of money\nsolicited. In this regard, the GICLUBS website stated, in substance and in part, that members with\nmultiple memberships would \"receive additional benefits\" when, in truth and in fact, and as\nKWOK and JE well knew, multiple memberships did not provide members with additional\nbenefits.\n16. All told, investors purchased hundreds of millions of dollars' worth of GIC LUBS\nmemberships. However, most of this money did not fund the business of GICLUBS. Rather, HO\nWAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother\nSeven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others\nknown and unknown, misappropriated a substantial portion of the funds victims had paid\nGICLUBS for \"memberships,\" using, among other things, a complex web of entities and bank\naccounts to do so. For example:\na. GICLUBS funds, which had been funneled through bank accounts in other\nentities' names, were used to pay personal expenses for KWOK and his family, including luxury\npurchases of an approximately $2.6 million yacht and luxury automobiles that together cost more\nthan $5 million.\nb. In or about November 2021, JE directed approximately $26.5 million of\nGICLUBS funds, which ·had been funneled through bank accounts in other entities' names, toward\nthe purchase of KWOK's 50,000 square foot New Jersey mansion.\nc. JE directed the transfer of an additional $13 million of GICLUBS\nmembership payments to an escrow account. The funds were subsequently used to pay for\nextravagant renovations to KWOK's New Jersey mansion, including to a wing for Relative-I and\n14\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g5e o3f1 4 o0f 56\nto a wing for Relative-2, and to purchase various furniture and decorative items including, among\nother items, Chinese and Persian rugs worth approximately $978,000, a $62,000 television, and\na $53,000 fireplace log cradle holder.\nd. On or about August 5, 2021, JE directed the transfer of approximately $1.1\nmillion consisting of GICLUBS membership payments into a bank account that JE controlled.\ne. GICLUBS used membership fees to purchase luxury automobiles, including\na custom-built Bugatti sports car for approximately $4.4 million. While the car's signed purchase\nagreement listed GICLUBS as the customer, the initial specifications documentation for the\ncustom-built car named Relative-I as the customer. Relative-I had no official position with\nGICLUBS.\nThe Himalaya Exchange\n17. From at least in or about April 2021 through at least in or about March 2023, HO\nWAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother\nSeven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a \"William Je,\" the defendants, and others\nknown and unknown, fraudulently obtained more than approximately $262 million in victim funds\nthrough the Himalaya Exchange, a purported cryptocurrency \"ecosystem\" accessible on the\ninternet. The Himalaya Exchange included a purported stablecoin called the Himalaya Dollar\n(\"HDO\" or \"H Dollar\") and a trading coin called Himalaya Coin (\"HCN\" or \"H Coin\"). The\nHimalaya Exchange claimed that the \"stablecoin\" was a digital asset with a fixed l-to-$1 value\nbacked by reserves, and that the \"trading coin\" was a cryptocurrency with valuation based on\nsupply and demand. JE was the founder and Chairman of the Himalaya Exchange.\n18. In videos distributed via social media, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the defendant,\n15\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g6e o3f2 4 o0f 56\ntrumpeted the prospects and valuation of the Himalaya Exchange and both HCN and HDO, which\nhe publicly described as cryptocurrencies. For example, in a video posted on the Internet on or\nabout October 20, 2021, KWOK falsely stated the following, among other things, and in substance\nand in part:\na. \"I am talking about your H Coins, 'Brother Seven' [i.e., KWOK] designed\nit ....[ I]t has the attribute of currency, why? It has 20% gold. Awesome[.] [I]t was born as\ncurrency on the first day, so it has value and it is linked to gold ... clear gold directly. No matter\nhow much it raises, 20% will turn into gold.\"\nb. \"If the H Coin is worthless, [the issuer of H coin] can sell all 20% of the\ngold, exchange it to you, and become your money. Or take all the value of 20% gold and ask\neveryone to unify it and make it yours.\"\nc. \"If anyone loses money, I can say that I will compensate 100%. I give you\n100%. Whoever loses money, I will bear it.\"\nd. \"I can sell the H Coin in the market in one minute and get it back to my\nH Dollar, and back to your fiat money unit. ... [A]nd you can buy anything immediately.\"\n19. The initial coin offering ofHCN and HDO occurred on or about November 1, 2021.\nHCN began trading at 10 cents and, within approximately two weeks, the Himalaya Exchange\nwebsite claimed that each HCN purportedly was worth approximately 27 HDO (i.e., $27), which\nrepresented a 26,900% increase in value. That is, approximately two weeks after the initial coin\noffering, the Himalaya Exchange website indicated that HCN purportedly had an approximately\n$27 billion valuation.\n20. At the time of the Himalaya Exchange launch, HO WAN KWOK, a/k/a \"Miles\nGuo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" the\n16\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g7e o3f3 4 o0f 56\ndefendant, marketed HCN to his online followers and others. For example, on or about November\n1, 2021-the day of the initial coin offering-KWOK released an official music video for an\noriginal song called \"HCoin To the Moon\" via social media. The phrase \"to the moon\" is popularly\nassociated with cryptocurrencies and implies a sharp increase in value. The music video depicted\nKWOK in various luxurious locations and depicted imagery of gold and wealth.\n21. At times, including following the Himalaya Exchange launch, KIN MING JE, a/k/a\n\"William Je,\" the defendant, misleadingly marketed the Himalaya Exchange. For example, in or\nabout June 2022, JE attempted to create the impression that a 3€ ,561,127 purchase of a Ferrari (the\n\"Ferrari\") from a particular auction house was completed with HDO. JE stated, in substance and\nin part, that he was \"extremely pleased that [a] buyer decided to purchase [a] world-class car using\nHDO.\" Contrary to JE' s claim, the Ferrari was not purchased using HDO. In truth and in fact,\nand as JE well knew, a Himalaya Exchange employee sent the auction house an international bank\nwire to cover the cost of the Ferrari, while also processing a corresponding \"transaction\" on the\nHimalaya Exchange to create the false appearance that the purchase had taken place using HDO.\nJE's statement was also misleading in that, among other things, the unidentified \"buyer\" of the\nFerrari was, in fact, Relative-I.\n22. Contrary to representations of HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles\nKwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE,\na/k/a \"William Je,\" the defendants, and others known and unknown, HCN and HDO could not be\ntraded anywhere other than (purportedly) on the Himalaya Exchange. Moreover, unlike\ncryptocurrencies, HCN could not be traded for, or converted into, other currencies. HCN\npurportedly could be traded for only HDO ( and only on the Himalaya Exchange), and HDO\npurportedly only could be converted to or from fiat currency ( and only on the Himalaya Exchange).\n17\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g8e o3f4 4 o0f 56\na. Indeed, the HDO and HCN Whitepapers, available on the Himalaya\nExchange website, provided in fine print that, contrary to KWOK's representations, HCN and\nHDO were not cryptocurrencies. Rather, according to the HCN Whitepaper, the \"operation of the\nHimalaya Exchange and associated applications and infrastructure will be facilitated through the\nuse of 'Credits.\"' Those credits (i) could \"only be used on the Himalaya Exchange or within the\nHimalaya Ecosystem,\" and (ii) did \"not carry any right to require their exchange for fiat currency\nor crypto-assets.\" Moreover, while Himalaya Exchange members could request to exchange their\n\"HDO\" credits for an equivalent payment in U.S. dollars, the HDO Whitepaper stated that the\nHimalaya Exchange had the \"discretion\" to deny any such request.\n23. In or about April 2022, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\"\na/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING JE, a/k/a\n\"William Je,\" the defendants, arranged for the transfer of approximately $37 million in Himalaya\nExchange funds from a Himalaya Exchange bank account to a particular escrow account. The $3 7\nmillion was structured as a purported \"loan\" to cover the cost of a luxury yacht that KWOK had\npreviously purchased and used, which yacht was then-owned by an entity held in the name of\nRelative-2.\nGovernment Seizure ofF raud Proceeds\n24. On or about September 20, 2022 and September 21, 2022, U.S. authorities served\njudicially-authorized seizure warrants on several domestic banks, and subsequently seized\napproximately $335 million of proceeds from bank accounts held in the names of Himalaya\nExchange entities and other entities associated with HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING\nJE, a/k/a \"William Je,\" the defendants. Following the September 2022 judicially authorized\n18\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 1g9e o3f5 4 o0f 56\nseizures, JE attempted to transfer approximately $46 million from domestic bank accounts\nassociated with the Himalaya Exchange, which had not yet been seized by the United States, to a\nbank account in the UAE that JE controlled.\na. Within approximately two days of the first judicially authorized seizures of\nHimalaya Exchange-related funds, on or about September 22, 2022, JE contacted the management\nof a domestic bank that held Himalaya Exchange bank accounts. JE sought to implement a wire\ntransfer, which he and a Himalaya Exchange executive claimed to the domestic bank was needed\nto effectuate a \"redemption\" from HDO to U.S. dollars for an unnamed \"VIP\" (i.e., very important\nclient of the Himalaya Exchange).\nb. In subsequent communications with the domestic bank, JE revealed that the\nVIP was, in fact, JE himself. JE provided the domestic bank with documents reflecting two\npurported HCN sales by JE on or about September 22, 2022-totaling 46 million HDO, which JE\nwas attempting to \"convert\" into $46 million. JE twice emphasized to the domestic bank's\nmanagement, in substance and in part, that the $46 million transfer needed to happen \"today or it\nis meaningless.\"\n25. On or about October 16, 2022, pursuant to a judicially authorized warrant, U.S.\nauthorities seized an additional approximately $274 million of proceeds from several Himalaya\nExchange and GICLUBS accounts at the domestic bank from which JE requested the $46 million\ntransfer.\na. As a result of the judicially-authorized seizures, U.S. authorities seized\nmore than approximately $634 million of fraud proceeds, including approximately $278 million\nfrom bank accounts held in the names of the Himalaya Exchange entities, including accounts that\npurported to hold its HDO cash reserves.\n19\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g0e o3f6 4 o0f 56\nb. Following the seizures, the Himalaya Exchange website continued to\nrepresent that HDO was backed by a \"Reserve consisting of USD and cash-equivalent assets\"\nwhen, in truth and in fact, it was not.\nc. Despite the seizure of the Himalaya Exchange' s cash reserves, the\npurported price ofHCN had not suddenly and sharply declined through the date ofthis Indictment.\nSTATUTORY ALLEGATIONS\n26. From at least in or about 2018 up to and including at least in or about March 2023,\nin the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" KIN MING\nJE, a/k/a \"William Je,\" and Y ANPING WANG, a/k/a \"Yvette,\" the defendants, and others known\nand unknown, willfully and knowingly combined, conspired, confederated, and agreed together\nand with each other to commit offenses against the United States, to wit, ( 1) wire fraud, in violation\nof Title 18, United States Code, Section 1343; (2) securities fraud, in violation of Title 15, United\nStates Code, Sections 78j(b) & 78ff, and Title 17, Code of Federal Regulations, Section 240.1 0b-\n5; (3) bank fraud, in violation of Title 18, United States Code, Section 1344; (4) international\npromotional money laundering, in violation of Title 18, United States Code, Section\n1956(a)(2)(A); and (5) international concealment money laundering, in violation of Title 18,\nUnited States Code Section 1956(a)(2)(B)(i).\n27. It was a part and an object of the conspiracy that HO WAN KWOK, a/k/a \"Miles\nGuo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\"\nKIN MING JE, a/k/a \"William Je,\" and Y ANPING WANG, a/k/a \"Yvette,\" the defendants, and\nothers known and unknown, knowingly having devised and intending to devise a scheme and\nartifice to defraud, and for obtaining money and property by means of false and fraudulent\n20\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g1e o3f7 4 o0f 56\npretenses, representations, and promises, would and did transmit and cause to be transmitted by\nmeans of wire, radio, and television communication in interstate and foreign commerce, writings,\nsigns, signals, pictures, and sounds for the purpose of executing such scheme and artifice, in\nviolation of Title 18, United States Code, Section 1343, to wit, KWOK, JE, and WANG agreed to\nobtain victims' money by causing materially false information and misrepresentations to be\ntransmitted over interstate wires, in connection with the GTV Private Placement, the Farm Loan\nProgram, GICLUBS, and the Himalaya Exchange.\n28. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" KIN MING JE, a/k/a \"William Je,\" and YANPING WANG, a/k/a \"Yvette,\" the\ndefendants, and others known and unknown, willfully and knowingly, directly and indirectly, by\nuse of a means and instrumentality of interstate commerce and of the mails, and of a facility of a\nnational securities exchange, used and employed, in connection with the purchase and sale of a\nsecurity registered on a national securities exchange and any security not so registered, a\nmanipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal\nRegulations, Section 240.l0b-5, by (a) employing a device, scheme and artifice to defraud; (b)\nmaking an untrue statement of material fact and omitting to state a material fact necessary in order\nto make the statement made, in light of the circumstances under which it was made, not misleading;\nand (c ) engaging in an act, practice and course of business which operated and would operate as a\nfraud and deceit upon a person, to wit, KWOK, JE, and WANG agreed to fraudulently induce\ninvestors to participate in the GTV Private Placement, the Farm Loan Program, and GICLUBS by\nproviding materially false and misleading information and representations in connection with\npurported shares of GTV common stock and purported companies affiliated with GTV.\n21\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g2e o3f8 4 o0f 56\n2 9. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" KIN MING JE, a/k/a \"William Je,\" and YANPING WANG, a/k/a \"Yvette,\" the\ndefendants, and others known and unknown, knowingly would and did execute and attempt to\nexecute a scheme and artifice to defraud a financial institution, as defined in Title 18, United States\nCode, Section 20, and to obtain moneys, funds, credits, assets, securities, and other property owned\nby, and under the custody and control of, such a financial institution, by means of false and\nfraudulent pretenses, representations, and promises, in violation of Title 18, United States Code,\nSection 1344, to wit, KWOK, JE,,and WANG agreed to participate in a scheme to mislead U.S.\nfinancial institutions through false and fraudulent pretenses, representations, and documents, in\nconnection with the GTV Private Placement, the Farm Loan Program, GICLUBS, and the\nHimalaya Exchange, in order to obtain money of, or under the custody and control of, at least one\nfinancial institution.\n30. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" KIN MING JE, a/k/a \"William Je,\" and Y ANPING WANG, a/k/a \"Yvette,\" the\ndefendants, and others known and unknown, would and did transport, transmit, and transfer, and\nattempt to transport, transmit, and transfer, a monetary instrument and funds from a place in the\nUnited States to and through a place outside the United States, and to a place in the United States\nfrom and through a place outside the United States, with the intent to promote the carrying on\nspecified unlawful activity, to wit, the offenses alleged in Counts Two through Eight of this\nIndictment in violation of Title 18, United States Code, Section l 956(a)(2)(A)(i).\n22\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g3e o3f9 4 o0f 56\n31. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a\n\"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" KIN MING JE, a/k/a \"William Je,\" and YA NPING WANG, a/k/a \"Yvette,\" the\ndefendants, and others known and unknown, would and did transport, transmit, and transfer, and\nattempted to transport, transmit, and transfer, a monetary instrument and funds from a place in the\nUnited States to and through a place outside the United States, and to a place in the United States\nfrom and through a place outside the United States, knowing that the monetary instrument and\nfunds involved in the transportation, transmission, and transfer represent the proceeds of some\nform of unlawful activity, and knowing that such transportation, transmission, and transfer is\ndesigned in whole and in part to conceal and disguise the nature, location, source, ownership, and\ncontrol of the proceeds of specified unlawful activity, to wit, the offenses alleged in Counts Two\nthrough Eight of this Indictment, in violation of Title 18, United States Code, Section\n1956(a)(2)(B)(i).\nOvert Acts\n32. In furtherance of the conspiracy and to effect its illegal objects, HO WAN KWOK,\na/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The\nPrincipal,\" KIN MING JE, a/k/a \"William Je,\" and YA NPING WANG, a/k/a \"Yvette,\" the\ndefendants, and others known and unknown, committed the following overt acts, among others, in\nthe Southern District of New York and elsewhere:\na. On or about April 21, 2020, KWOK posted, and caused to be posted, a video\non social media announcing the unregistered offering of GTV stock via the GTV Private\nPlacement.\n23\n\n..\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g4e o4f0 4 o0f 56\nb. On or about June 5, 2020, WANG, while located in the Southern District of\nNew York, authorized a wire transfer of $100 million from Saraca to Fund-1.\nc. On or about July 22, 2020, in a video distributed via social media, KWOK\npromoted the Farm Loan Program.\nd. On or about August 2, 2020, in a video distributed via social media, KWOK\nstated, in substance and part, \"How much is GTV? ... a market value of 2 billion US dollars.\"\ne. On or about May 28, 2021, JE transferred approximately $13 million from\na bank account in the UAE that JE controlled to a bank account held by an entity (owned by\nRelative-2) at a particular bank in New York, New York.\nf. On or about July 30, 2021, in a video distributed via social media, KWOK\nstated, in substance and in part, \"Some of the comrades in arms asked, ' [w ]ill I still get a free stock\noffer when I buy a G-Clubs membership?' 100%. Because I said that I have to promise that [to]\nanyone who buys G-Clubs membership before September 17 [they] must be allotted shares, which\nis exactly the same. Because we said that anyone can choose whether to use your money to buy\nG-Clubs before September 17, G-Clubs and the stock shares. You'll get both.\"\ng. On or about August 5, 2021, JE directed the transfer of approximately $1.1\nmillion consisting of funds victims had sent to GICLUBS in exchange for \"memberships\" to a\nbank account that JE controlled.\nh. On or about October 20, 2021, in a video distributed via social media,\nKWOK stated, in substance and in part, that KWOK \"designed\" HCN, that \"[n]o matter how much\nit raises, 20% will tum into gold,\" and that \"[i]f anyone loses money\" on HCN, \"I can say that I\nwill compensate 100%.\"\n24\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g5e o4f1 4 o0f 56\nOn or about September 22, 2022, JE texted a U.S. bank's management, in\n1.\nsubstance and in part, that a $46 million transfer to a JE-controlled bank account in the UAE\nneeded to happen \"today or it is meaningless.\"\n(Title 18, United States Code, Section 371.)\nCOUNT TWO\n(Wire Fraud - GTV Private Placement)\nThe Grand Jury further charges:\n33. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n34. From at least in or about April 2020 up to and including at least in or about March\n2021, in the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" KIN\nMING JE, a/k/a \"William Je,\" and Y ANPING WANG, a/k/a \"Yvette,\" the defendants, knowingly\nhaving devised and intending to devise a scheme and artifice to defraud, and for obtaining money\nand property by means of false and fraudulent pretenses, representations, and promises, transmitted\nand caused to be transmitted by means of wire, radio, and television communication in interstate\nand foreign commerce, writings, signs, signals, pictures, and sounds, for the purpose of executing\nsuch scheme and artifice, to wit, KWOK, JE, and WANG conducted the GTV Private Placement\nto sell GTV stock and fraudulently obtain money from victims through false statements and\nmisrepresentations, which scheme was furthered through electronic communications and monetary\ntransfers to and from the Southern District of New York and elsewhere.\n(Title 18, United States Code, Sections 1343 and 2.)\n25\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g6e o4f2 4 o0f 56\nCOUNT THREE\n(Securities Fraud - GTV Private Placement)\nThe Grand Jury further charges:\n35. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n36. From at least in or about April 2020 up to and including at least in or about March\n2021, in the Southern District ofNew York, and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" KIN\nMING JE, a/k/a \"William Je,\" and Y ANPING WANG, a/k/a \"Yvette,\" the defendants, willfully\nand knowingly, directly and indirectly, by use of a means and instrumentality of interstate\ncommerce and of the mails, and of a facility of a national securities exchange, used and employed,\nin connection with the purchase and sale of a security registered on a national securities exchange\nand any security not so registered, a manipulative and deceptive device and contrivance, in\nviolation of Title 17, Code of Federal Regulations, Section 240.lOb-5, by (a) employing a device,\nscheme and artifice to defraud; (b) making an untrue statement of material fact and omitting to\nstate a material fact necessary in order to make the statement made, in light of the circumstances\nunder which it was made, not misleading; and ( c) engaging in an act, practice and course of\nbusiness which operated and would operate as a fraud and deceit upon a person, to wit, KWOK,\nJE, and WANG conducted the GTV Private Placement to sell GTV stock and obtain money from\nvictims through false statements and misrepresentations, which scheme was furthered through\nelectronic communications and monetary transfers to and from the Southern District of New York\nand elsewhere.\n(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal Regulations,\nSection 240.1 0b-5; and Title 18, United States Code, Section 2.)\n26\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g7e o4f3 4 o0f 56\nCOUNT FOUR\n(Wire Fraud - Farm Loan Program)\nThe Grand Jury further charges:\n3 7. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n38. From at least in or about June 2020 up to and including at least in or about March\n2023, in the Southern District of New York and elsewhere, HOWA N KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, knowingly having devised and intending to devise\na scheme and artifice to defraud, and for obtaining money and property by means of false and\nfraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by\nmeans of wire, radio, and television communication in interstate and foreign commerce, writings,\nsigns, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,\nKWOK and JE conducted the Farm Loan Program to fraudulently obtain money from victims\nthrough false statements and misrepresentations, which scheme was furthered through electronic\ncommunications and monetary transfers to and from the Southern District of New York and\nelsewhere.\n(Title 18, United States Code, Sections 1343 and 2.)\nCOUNT FIVE\n(Securities Fraud-Farm Loan Program)\nThe Grand Jury further charges:\n39. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n27\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g8e o4f4 4 o0f 56\n40. From at least in or about June 2020 up to and including at least in or about March\n2023, in the Southern District of New York, and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, willfully and knowingly, directly and indirectly, by\nuse of a means and instrumentality of interstate commerce and of the mails, and of a facility of a\nnational securities exchange, used and employed, in connection with the purchase and sale of a\nsecurity registered on a national securities exchange and any security not so registered, a\nmanipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal\nRegulations, Section 240. lOb-5, by (a) employing a device, scheme and artifice to defraud;\n(b) making an untrue statement of material fact and omitting to state a material fact necessary in\norder to make the statement made, in light of the circumstances under which it was made, not\nmisleading; and ( c) engaging in an act, practice and course of business which operated and would\noperate as a fraud and deceit upon a person, to wit, KWOK and JE conducted the Farm Loan\nProgram to obtain money from victims through false statements and misrepresentations, including\nregarding, among other things, the value of GTV, which scheme was furthered through electronic\ncommunications and monetary transfers to and from the Southern District of New York and\nelsewhere.\n(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal Regulations,\nSection 240.1 0b-5; and Title 18, United States Code, Section 2.)\nCOUNT SIX\n(Wire Fraud - GICLUBS)\nThe Grand Jury further charges:\n41. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n28\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 2g9e o4f5 4 o0f 56\n42. From at least in or about June 2020 up to and including at least in or about March\n2023, in the Southern District of New York and elsewhere, HOWA N KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, knowingly having devised and intending to devise\na scheme and artifice to defraud, and for obtaining money and property by means of false and\nfraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by\nmeans of wire, radio, and television communication in interstate and foreign commerce, writings,\nsigns, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,\nKWOK and JE promoted and marketed GICLUBS to fraudulently obtain money from victims\nthrough false statements and misrepresentations, which scheme was furthered through electronic\ncommunications and monetary transfers to and from the Southern District of New York and\nelsewhere.\n(Title 18, United States Code, Sections 1343 and 2.)\nCOUNT SEVEN\n(Securities Fraud-GICLUBS)\nThe Grand Jury further charges:\n43. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n44. From at least in or about June 2020 up to and including at least in or about March\n2021, in the Southern District of New York, and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, willfully and knowingly, directly and indirectly, by\nuse of a means and instrumentality of interstate commerce and of the mails, and of a facility of a\nnational securities exchange, used and employed, in connection with the purchase and sale of a\n29\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g0e o4f6 4 o0f 56\nsecurity registered on a national securities exchange and any security not so registered, a\nmanipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal\nRegulations, Section 240.l0b-5, by (a) employing a device, scheme and artifice to defraud;\n(b) making an untrue statement of material fact and omitting to state a material fact necessary in\norder to make the statement made, in light of the circumstances under which it was made, not\nmisleading; and ( c) engaging in an act, practice and course of business which operated and would\noperate as a fraud and deceit upon a person, to wit, KWOK and JE promoted and marketed\nG\\CLUBS to obtain money from victims through false statements and misrepresentations,\nincluding regarding, among other things, the value of GTV, which scheme was furthered through\nelectronic communications and monetary transfers to and from the Southern District of New York\nand elsewhere.\n(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal\nRegulations, Section 240.10 b-5; and Title 18, United States Code, Section 2.)\nCOUNT EIGHT\n(Wire Fraud-The Himalaya Exchange)\nThe Grand Jury further charges:\n45. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n46. From at least in or about April 2021 up to and including at least in or about March\n2023, in the Southern District of New York and elsewhere, HOWA N KWOK, a/k/a \"Miles Guo,\"\na/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN\nMING JE, a/k/a \"William Je,\" the defendants, knowingly having devised and intending to devise\na scheme and artifice to defraud, and for obtaining money and property by means of false and\nfraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by\nmeans of wire, radio, and television communication in interstate and foreign commerce, writings,\n30\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g1e o4f7 4 o0f 56\nsigns, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,\nKWOK and JE operated the Himalaya Exchange to fraudulently obtain money from victims\nthrough false statements and misrepresentations, which scheme was furthered through electronic\ncommunications and monetary transfers to and from the Southern District of New York and\nelsewhere.\n(Title 18, United States Code, Sections 1343 and 2.)\nCOUNT NINE\n(International Promotional Money Laundering)\nThe Grand Jury further charges:\n4 7. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n48. From at least in or about 2018 up to and including at least in or about March 2023,\nin the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING\nJE, a/k/a \"William Je,\" the defendants, did transport, transmit, and transfer, and attempt to\ntransport, transmit, and transfer, a monetary instrument and funds from a place in the United States\nto and through a place outside the United States, and to a place in the United States from and\nthrough a place outside the United States, with the intent to promote the carrying on specified\nunlawful activity, to wit, KWOK and JE directed and made international transfers of funds into,\nout of, and through the United States, with the intent to promote the fraud offenses in Counts Two\nthrough Eight of the Indictment.\n(Title 18, United States Code, Sections 1956(a)(2)(A) and 2.)\n31\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g2e o4f8 4 o0f 56\nCOUNT TEN\n(International Concealment Money Laundering)\nThe Grand Jury further charges:\n49. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n50. From at least in or about 2018 up to and including at least in or about March 2023,\nin the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a\n\"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" and KIN MING\nJE, a/k/a \"William Je,\" the defendants, did transport, transmit, and transfer, and attempt to\ntransport, transmit, and transfer, a monetary instrument and funds from a place in the United States\nto and through a place outside the United States, and to a place in the United States from and\nthrough a place outside the United States, knowing that the monetary instrument and funds\ninvolved in the transportation, transmission, and transfer represented the proceeds of some form\nof unlawful activity, and knowing that such transportation, transmission, and transfer was designed\nin whole and in part to conceal and disguise the nature, location, source, ownership, and control\nof the proceeds of specified unlawful activity, namely, the fraud offenses alleged in Counts Two\nthrough Eight of this Indictment, to wit, KWOK and JE conducted international financial\ntransactions into, and out of, and through the United States involving fraud proceeds, including,\namong other transactions, transactions involving bank accounts held in the names of entities\nnominally owned by other individuals and by entities not overtly associated with the defendants,\nin order to conceal the ownership, control, and/or receipt of the proceeds of the fraud and the illegal\nnature and source of such proceeds.\n(Title 18, United States Code, Sections 1956(a)(2)(B)(i) and 2.)\n32\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g3e o4f9 4 o0f 56\n\\\nCOUNT ELEVEN\n(Unlawful Monetary Transactions)\nThe Grand Jury further charges:\n51. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n52. On or about June 5, 2020, in the Southern District of New York and elsewhere, HO\nWAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother\nSeven,\" a/k/a \"The Principal,\" KIN MING JE, a/k/a \"William Je,\" and YA NPING WANG, a/k/a\n\"Yvette,\" the defendants, within the United States, knowingly engaged and attempted to engage\nin a monetary transaction, as defined in Title 18, United States Code, Section 1957(£)(1), in\ncriminally derived property of a value greater than $10,000 that was derived from specified\nunlawful activity, to wit, KWOK, JE, and WANG made, and directed others to make, a wire\ntransfer of approximately $100 million derived from the offenses charged in Counts Two and\nThree to Fund-1.\n(Title 18, United States Code, Sections 1957 and 2.)\nCOUNT TWELVE\n(Obstruction of Justice)\nThe Grand Jury further charges:\n53. The allegations contained in paragraphs 1 through 25 of this Indictment are\nrepeated and realleged as if fully set forth herein.\n54. From at least on or about September 20, 2022 through the date of the filing of this\nIndictment, in the Southern District of New York and elsewhere, KIN MING JE, a/k/a \"William\nJe,\" the defendant, corruptly obstructed, influenced, and impeded an official proceeding and\nattempted so to do, to wit, JE attempted to transfer money to the UAE, beyond the jurisdiction of\n33\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g4e o5f0 4 o0f 56\nthe United States, to impede and interfere with a federal grand jury investigation in the Southern\nDistrict of New York of the offenses alleged in Counts One through Eleven of this Indictment, and\nproceedings before the United States District Court for the Southern District of New York\nconcerning the seizure and forfeiture of criminally derived proceeds.\n(Title 18, United States Code, Sections 1512(c)(2) and 2.)\nFORFEITURE ALLEGATIONS\n55. As a result of committing the offenses alleged in Counts One through Eight of this\nIndictment, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles Kwok,\" a/k/a \"Guo Wengui,\"\na/k/a \"Brother Seven,\" a/k/a \"The Principal,\" KIN MING JE, a/k/a \"William Je,\" and Y ANPING\nWANG, a/k/a \"Yvette,\" the defendants, shall forfeit to the United States, pursuant to Title 18,\nUnited States Code, Section 981(a)(l)(C) and Title 28 United States Code, Section 2461(c), any\nand all property, real and personal, that constitutes or is derived from proceeds traceable to the\ncommission of said offenses, including but not limited to a sum of money in United States currency\nrepresenting the amount of proceeds traceable to the commission of said offenses and, and the\nfollowing specific property:\na. $64,826.87 in United States currency formerly on deposit in Account\nNumber 5090037713 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\nb. $75,000,000.00 in United States currency formerly on deposit in Account\nNumber 5090037705 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\n34\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g5e o5f1 4 o0f 56\nl\nc. $467,343.00 in United States currency formerly on deposit in Account\nNumber 5090037754 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\nd. $89,992,861.75 in United States currency formerly on deposit in Account\nNumber 5090042770 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\ne. $1,683,077.40 in United States currency formerly on deposit in Account\nNumber 5090042762 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\nf. $85,899,889.20 in United States currency formerly on deposit in Account\nNumber 5090042853 at Silvergate Bank held in the name of\"Hamilton Opportunity Funds SPC,\"\nseized by the Government on or about September 18, 2022;\ng. $48,230,709.62 in United States currency formerly on deposit in Account\nNumber 5090030288 at Silvergate Bank held in the name of\"Hamilton Investment Management\"\nLtd., seized by the Government on or about September 18, 2022;\nh. $1,800,000.00 in United States currency formerly on deposit in Account\nNumber 5090037739 at Silvergate Bank held in the name of \"Hamilton Opportunity Fund SPC,\"\nseized by the Government on or about September 18, 2022;\ni. $85,899,889.20 in United States currency formerly on deposit in Account\nNumber 5090042853 at Silvergate Bank held in the name of\"Hamilton Opportunity Funds SPC,\"\nseized by the Government on or about September 18, 2022;\n35\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g6e o5f2 4 o0f 56\nj. $4,643,744.70 in United States currency formerly on deposit in Account\nNumber 7801000590 at FV Bank held in the name of \"Himalaya International Reserves, Ltd.,\"\nseized by the Government on or about September 20, 2022;\nk. $14,599,257.25 in United States currency formerly on deposit in Account\nNumber 7801000254 at FV Bank held in the name of \"Himalaya International Clearing, Ltd.,\"\nseized by the Government on or about September 20, 2022;\n1. $11,538,579.87 in United States currency formerly on deposit in Account\nNumber MBI10103-0000 at Mercantile Bank International held in the name of \"G Club\nInternational Ltd.,\" seized by the Government on or about October 16, 2022;\nm. $10,008,284.04 in United States currency formerly on deposit in Account\nNumber MBil 0133-0000 at Mercantile Bank International held in the name of \"Himalaya\nInternational Clearing Ltd.,\" seized by the Government between on or about October 16, 2022 and\non or about March 10, 2023;\nn. $3,090,856.54 in United States currency formerly on deposit in Account\nNumber MBI10137-0000 at Mercantile Bank International held in the name of \"Hamilton Capital\nHolding Ltd.,\" seized by the Government between on or about October 16, 2022 and on or about\nMarch 10, 2023;\no. $272,350,313.76 in United States currency formerly on deposit in Account\nNumber MBI10138-0000 at Mercantile Bank International held in the name of \"Himalaya\nInternational Reserves Ltd.,\" seized by the Government between on or about October 16, 2022 and\non or about March 10, 2023;\np. $310,594.31 in United States currency formerly on deposit in Account\nNumber MBI10139-0000 at Mercantile Bank International held in the name of \"Himalaya\n36\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g7e o5f3 4 o0f 56\nInternational Financial Group Ltd.,\" seized by the Government between on or about October 16,\n2022 and on or about March 10, 2023;\nq. $1,187,278.87 in United States currency formerly on deposit in Account\nNumber MBI10171-0000 at Mercantile Bank International held in the name of \"Hamilton\nInvestment Management Ltd.,\" seized by the Government between on or about October 16, 2022\nand on or about March 10, 2023;\nr. $43,782.71 in United States currency formerly on deposit in Account\nNumber MBI10172-0000 at Mercantile Bank International held in the name of \"G Fashion\nInternational Limited,\" seized by the Government on or about October 16, 2022;\ns. $161,809.47 in United States currency formerly on deposit in Account\nNumber MBI10183-0000 at Mercantile Bank International held in the name of \"Himalaya\nCurrency Clearing Pty Ltd.,\" seized by the Government on or about October 16, 2022;\nt. $2,745,377.75 in United States currency formerly on deposit in Account\nNumber 9878904409 at Manufacturers & Traders Trust Co. held in the name of \"GETTR USA,\nInc.,\" seized by the Government on or about September 18, 2022;\nu. $9,899,659.19 in United States currency formerly on deposit in Account\nNumber 157525208185 at US Bank held in the name of \"G Fashion,\" seized by the Government\non or about September 18, 2022;\nv. All that lot or parcel of land, together with its buildings, appurtenances,\nimprovements, fixtures, attachments, and easements, located at 675 Ramapo Valley Road,\nMahwah, New Jersey 07430, Parcel No. 3300021-03-00001-02 and described as Lot Number: 1.02\nBlock: 21.03 District: 33 City, Municipality, Township: MAHWAH TWP\n37\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g8e o5f4 4 o0f 56\n♦\nf •\nw. A Bugatti Chiron Super Sport, bearing Vehicle Identification Number\nVF9SW3V3XNM795047;\nx. A Lamborghini Aventador SVJ Roads, bearing Vehicle Identification\nNumber ZHWUN6ZD2MLA10393;\ny. A Rolls Royce Phantom EWB, bearing Vehicle Identification Number\nSCAT T8C08MU206445;\nz. A 46m 2014 Feadship superyacht \"Lady May\" (ex Como), bearing IMO\nNumber 112359, MMSI Number 319059500, and Callsign ZGDQ9;\naa. A Bosendorfer 185VC Porsche #49539 piano with custom bench, purchased\nfor approximately $140,938.69;\nbb. A Railis Design Iceland Contemporary Poseidon Bed with Nightstands,\nEbony Veneer, Brass, Velvet, purchased for approximately $31,413.71;\ncc. A Hastens 2000T md mattress, purchased for approximately $36,590.00;\ndd. A Hastens 2000T sf mattress, purchased for approximately $36,210.00;\nee. A Wembe watch storage box, purchased for approximately $59,392.91;\nff. A Samsung Q900 Series QN98Q900RBF 98\" QLED Smart TV - 8K,\npurchased for approximately $62,787.54;\ngg. A Louis XV Style French Ormolu-Mounted Mahogany Commode by\nJoseph Emmanuel Zweiner;\nhh. A \"K'ang Hsi\" extension table in etched and patinated pewter and bronze\nwith hand-painted enamel colors by Philip & Kelvin LaV erne, purchased for approximately\n$180,000.00; and\n38\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 3g9e o5f5 4 o0f 56\nii. A \"Punto '83\" table in stainless steel with mesh tabletop with adjustable\nheight and adjustable petals by Gabriella Crespi, Italy 1982, purchased for approximately\n$180,000.00.\n(a) through (ii), collectively, the \"Specific Property.\"\n56. As a result of committing the money laundering offenses alleged in Counts One,\nNine, Ten and Eleven of this Indictment, HO WAN KWOK, a/k/a \"Miles Guo,\" a/k/a \"Miles\nKwok,\" a/k/a \"Guo Wengui,\" a/k/a \"Brother Seven,\" a/k/a \"The Principal,\" KIN MING JE, a/k/a\n\"William Je,\" and YA NPING WANG, a/k/a \"Yvette,\" the defendants, shall forfeit to the United\nStates, pursuant to Title 18, United States Code, Section 982(a)(l), any and all property, real and\npersonal, involved in said offense, or any property traceable to such property, including but not\nlimited to a sum of money in United States currency representing the amount of property involved\nin said offense and the Specific Property.\nSubstitute Assets Provision\n57. If any of the above-described forfeitable property, as a result of any act or omission\nof the defendants:\na. cannot be located upon the exercise of due diligence;\nb. has been transferred or sold to, or deposited with, a third person;\nc. has been placed beyond the jurisdiction of the Court;\nd. has been substantially diminished in value; or\ne. has been commingled with other property which cannot be subdivided\nwithout difficulty;\n39\n\nCasCea 1s:e2 31-:c2r3-0-c0r1-01081-A18T- A T D o Dcoucmuemnet n7t1 169-6 F i lFeidle 0d3 0/279/2/283/2 5 P a g Pea 4g0e o5f6 4 o0f 56\n\\\nit is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and\nTitle 28, United States Code, Section 2461 ( c ), to seek forfeiture of any other property of the\ndefendants up to the value of the above forfeitable property.\n(Title 18, United States Code, Sections 981 and 982;\nTitle 21, United States Code, Section 853; and\nTitle 28, United States Code, Section 2461.)\n-\nJ:k--;_~\nDAMIAN WILLIAMS\nUnited States Attorney\ns\\,)''f eQ. ¼~ )~(,...\n~' L\\.. ..)_ND\"! CT°M <c:.N1\n1 !50\n40","body_zh":null,"key_entities":[],"ecf_references":[],"word_count":15961,"status":"published","published_at":"2025-07-28 00:00:00","created_at":"2025-07-28","updated_at":"2026-07-06 20:56:40"}