---
type: court_doc
id: "court_sdny_10_2"
court: "SDNY"
case_no: ""
doc_number: 10
doc_type: "DOC"
filed_date: null
lang: "zh"
url: "https://mubeitech.com/court/court_sdny_10_2"
json_url: "https://mubeitech.com/api/court/court_sdny_10_2"
---
# SDNY ECF 10



> 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。

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ORIGINAL
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA SEALED INDICTMENT
V. 23 Cr.
HO WAN KWOK,
a/k/a "Miles Guo,"
a/k/a "Miles Kwok,"
a/k/a "Guo Wengui,"
a/k/a "Brother Seven,"
a/k/a "The Principal,"
KINMINGJE,
...,
i
-~L ~u
a/k/a "William Je,"
Defendants.
COUNT ONE
(Conspiracy to Commit Wire Fraud, Securities Fraud, Bank Fraud, and
Money Laundering)
The Grand Jury charges:
Overview
1. From at least in or about 2018 through at least in or about March 2023, HO WAN
KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven,"
a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others known
and unknown, conspired to defraud thousands of victims of more than approximately $1 billion,
including victims located in the Southern District of New York. KWOK, JE, and their
co-conspirators operated through a series of complex fraudulent and fictitious businesses and
investment opportunities that connected dozens of interrelated entities, which allowed the
defendants and their co-conspirators to solicit, launder, and misappropriate victim funds.

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2. HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui,"
a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the
defendants, and their co-conspirators, took advantage of KWOK's prolific online presence and
hundreds of thousands of online followers to solicit investments in various entities and programs
by promising outsized financial returns and other benefits. The entities and programs used in the
scheme included those known as GTV, GICLUBS, GIMUSIC, GIFashion, and the Himalaya
Exchange, among others. In truth and in fact, and as KWOK and JE well knew, the entities were
instrumentalities that KWOK and JE created and used to perpetrate their fraud and exploit
KWOK's followers. The scheme allowed KWOK and JE to enrich themselves, their family
members, and their co-conspirators, and to fund KWOK's extravagant lifestyle.
3. As part of the scheme, HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok,"
a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE, a/k/a
"William Je," the defendants, and their co-conspirators, laundered hundreds of millions of dollars
of fraud proceeds. To conceal the illegal source of the funds, KWOK and JE transferred, and
directed the transfer of, money into and through more than approximately 500 accounts held in the
names of at least 80 different entities or individuals. Hundreds of millions of dollars of the
fraudulent scheme's proceeds were transferred, either directly or indirectly, to bank accounts in
the United States, Bahamas, and United Arab Emirates ("UAE"), among other places, and held in
the name of companies owned or otherwise controlled by JE.
4. HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui,"
a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the
defendants, used more than approximately $300 million of the fraudulent scheme's proceeds for
their and their families' benefit. For example, KWOK used fraudulently-obtained victim money
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to purchase, fund, or finance a $26.5 million purchase of an approximately 50,000-square-foot
mansion in New Jersey for KWOK and his family; luxury vehicles, including an approximately
$3.5 million Ferrari for one of KWOK's close family members ("Relative-I"); an approximately
$37 million luxury yacht that was used by KWOK and his family and purchased in the name of
one ofKWOK's close family members ("Relative-2"); a piano valued at approximately $140,000;
an approximately $36,000 mattress; and a $100 million investment in a high-risk hedge fund for
the ultimate benefit of Relative-I, among other things. For his part, , among other things, JE
transferred at least $10 million of the fraud proceeds into his and his spouse's personal bank
accounts.
5. HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui,"
a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the
defendants, and their co-conspirators, operated the scheme for years, and continued to do so at
least through the date of this Indictment. They did so, among other things, by continually adapting
the scheme's means and methods to evade the enforcement of investor-protection, anti-money
laundering, and bankruptcy laws in the United States, and by retaliating against individual victims
who complained or demanded the return of invested funds.
Relevant Persons and Entities
6. At all relevant times, HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok,"
a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," the defendant, was the leader
of, and directed, the scheme.
a. KWOK is an exiled Chinese businessman who fled to the United States in
or about 2015 and purchased a penthouse apartment at a New York City hotel for approximately
$67.5 million. Starting at least in or about 2017, KWOK, who then purported to be a billionaire,
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..
garnered a substantial online following. KWOK granted numerous media interviews and posted
on social media, claiming to advance a movement against the Chinese Communist Party.
b. In or about 2018, KWOK founded two purported nonprofit organizations,
namely, the Rule of Law Foundation and the Rule of Law Society. The Rule of Law Society's
website lists KWOK as its "founder, a promot[e]r, and a spokesperson." Both organizations
feature photographs of KWOK on their websites. KWOK used the nonprofit organizations to
amass followers who were aligned with his purported campaign against the Chinese Communist
Party and who were also inclined to believe KWOK's statements regarding investment and money
making opportunities. In truth and in fact, and as KWOK well knew, he and others provided false
and materially misleading information to promote these "opportunities" and to defraud KWOK's
followers and other victims.
7. At all relevant times, KIN MING JE, a/k/a "William Je," the defendant, was a dual
citizen of Hong Kong and the United Kingdom who principally resided in the United Kingdom,
while traveling to the United States and elsewhere. JE owned and operated numerous companies
and investment vehicles central to the scheme and served as its financial architect and key money
launderer.
8. At certain times relevant to this Indictment, Saraca Media Group, Inc. ("Saraca")
was a corporation based in New York, New York. Relative-I was its ultimate beneficial owner.
9. At certain times relevant to this Indictment, GTV Media Group, Inc. ("GTV") was
a purported news-focused social media platform based in New York, New York. GTV was
functionally owned and controlled by HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok,"
a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," the defendant, although
KWOK held no formal position or title at GTV. KIN MING JE, a/k/a "William Je," the defendant,
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likewise held no formal position or title at GTV, but in fact exercised control over its finances.
Saraca was the parent company of GTV.
10. At certain times relevant to this Indictment, G Club Operations, LLC ("G[CLUBS")
was a purported membership organization based in Puerto Rico and in New York, New York.
G[CLUBS was functionally owned and controlled by HO WAN KWOK, a/k/a "Miles Guo," a/k/a
"Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," the defendant,
although KWOK held no formal position or title at G[CLUBS. KIN MING JE, a/k/a "William Je,"
the defendant, likewise held no formal position or title at G[CLUBS, but in fact exercised control
over its finances.
11. At certain times relevant to this Indictment, the "Himalaya Exchange" was a
purported cryptocurrency "ecosystem" that KIN MING JE, a/k/a "William Je," the defendant,
founded and operated through various entities he owned, which were based abroad. Entities
functionally owned and controlled by HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok,"
a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," the defendant, such as
G[CLUBS and G[Fashion, had purported business relationships with the Himalaya Exchange.
KWOK promoted the Himalaya Exchange and claimed to be the designer of its purported
cryptocurrency, although KWOK held no formal position or title at the Himalaya Exchange.
The Fraud
The GTV Private Placement
12. Between in or about April 2020 and in or about June 2020, HOWA N KWOK, a/k/a
"Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The
Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others known and
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unknown, fraudulently obtained more than $400 million in victim funds through an illegal private
stock offering related to GTV (the "GTV Private Placement").
a. On or about April 21, 2020, KWOK posted, and caused to be posted, a video
on social media announcing the unregistered offering of GTV common stock via a private
placement. In that video, KWOK described, in substance and in part, the investment terms for the
GTV Private Placement, and directed people to contact him, via a mobile messaging application,
with any questions about the GTV Private Placement. The video and GTV Private Placement
materials-including the written "Confidential Information Memorandum" (the "PPM"),
Subscription Agreement, and Investment Procedure Guidelines-were transmitted to thousands of
potential investors, including those in the Southern District of New York, via mobile messaging
applications, social media, and text messages.
b. The PPM promoted GTV as the "first ever platform which will combine the
power of citizen journalism and social news with state-of-the-art technology, big data, artificial
intelligence, block-chain technology and real-time interactive communication."
c. According to the PPM' s metadata, JE was the "author" of the PPM. The
PPM disclosed the terms of the GTV Private Placement and identified KWOK as GTV's "Sponsor
and Adviser." According to the PPM, among other GTV materials, neither KWOK nor JE held
any formal management position with GTV.
d. The PPM also contained the following representations, in substance and in
part, among others:
The GTV Private Placement was for investors who were "interested
1.
in evaluating an opportunity to invest capital into GTV;"
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11. GTV planned to use the proceeds raised from the GTV Private
Placement "to expand and strengthen the business;" and
iii. The PPM included a chart itemizing the "contemplated use of
proceeds" raised from the GTV Private Placement:
Acquisition of companies to strengthen and grow
GTV
Upgrade of GTV technology and security Approximate 10%
Marketing Approximate 8%
Working capital Approximate 7%
Other Approximate 5%
Total 100%
e. Between on or about April 20, 2020 and on or about June 2, 2020,
approximately $452 million worth ofGTV common stock was purportedly sold to more than 5,500
investors located in the United States, including in the Southern District of New York, and abroad.
Investors participated in the GTV Private Placement based, in part, on the belief that their money
would be invested into GTV to develop and grow that business, as the PPM promised.
f. The vast majority of the proceeds derived from investors in the GTV Private
Placement were not used to develop and grow the GTV business, but instead were deposited
directly into bank accounts held in the name of Saraca, GTV's parent company, which is
beneficially owned by Relative-I.
g. The GTV Private Placement was not made pursuant to a registration
statement filed with the U.S. Securities and Exchange Commission ("SEC"). Rather, the offering
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was purportedly made pursuant to SEC regulations that permit the sale of unregistered securities
subject to limitations on the type of investors to whom the securities are offered and the manner in
which their investments may be solicited. To evade these limitations, however, KWOK, and others
under his control, used at least one intermediary entity to purchase GTV stock on behalf of pools
of investors who did not qualify to participate in the GTV Private Placement.
h. In or about early June 2020, and only days after the GTV Private Placement
closed, HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a
"Brother Seven," a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the defendants,
and their co-conspirators, misappropriated approximately $100 million raised from investors in
the GTV Private Placement and directed that those funds be placed with a high-risk hedge fund
("Fund-1 ") for the benefit of Saraca and its ultimate beneficial owner, Relative-I. This transaction
was contrary to the PPM's representations to prospective GTV investors about how investments
in GTV would be used. Indeed, the $100 million investment into Fund-1 was not made for the
benefit of GTV, but rather for the benefit of Saraca. The victims who supplied the $100 million
invested into Fund-1 did not own any shares of Saraca. Ultimately, the investment into Fund-1
lost approximately $30 million in value.
i. After directing $100 million of GTV victim funds into Fund-1, HO WAN
KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven,"
a/k/a "The Principal," the defendant, continued to promote GTV using false and misleading
representations.
The Farm Loan Program
13. Beginning in or about June 2020-the same month that HO WAN KWOK, a/k/a
"Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The
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Principal," and KIN MING JE, a/k/a "William Je," the defendants, and their co-conspirators
misappropriated money from the GTV Private Placement for the benefit of Saraca and
Relative-I-KWOK, JE, and their co-conspirators fraudulently obtained more than approximately
$150 million in victim funds through the "Himalaya Farm Alliance." The Himalaya Farm
Alliance, which KWOK organized and promoted, was a collective of informal groups ( each known
as a "Farm") located in various cities around the world. KWOK, JE, and others working on their
behalf and at their direction, obtained these funds by making further misrepresentations to the
investors in the GTV Private Placement and fraudulently soliciting further investments, this time
in the form of "loans" to a Farm, and promising that such loans would be convertible into GTV
common stock at a conversion rate of one share per dollar loaned (the "Farm Loan Program").
a. Starting in or about June 2020, domestic banks that held accounts used to
process the funds raised through the GTV Private Placement began to freeze and close GTV
associated bank accounts because, among other reasons, the accounts had received dozens oflarge
incoming wire transfers, some of which referenced an unregistered stock offering.
b. These bank account closures frustrated the ability of KWOK, JE, and their
co-conspirators to collect proceeds from victims seeking to invest in GTV.
c. On or about July 22, 2020, in a video distributed via social media, KWOK
promoted the Farm Loan Program. According to KWOK and those working on his behalf,
individuals seeking to invest (or reinvest) in GTV could participate in the Farm Loan Program.
d. After launching the Farm Loan Program, KWOK continued to promote
GTV and to falsely represent the value of GTV. For example, on or about August 2, 2020, in a
video distributed via social media, KWOK falsely stated, in substance and part, "How much is
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GTV? .. . a market value of2 billion US dollars."1 In truth and in fact, and as KWOK well knew,
GTV's market value was far less because, among other things, GTV was a new business that
generated no revenue.
e. Thousands of victims "loaned" money to the Farms by sending money to
bank accounts controlled by the Farms (and not GTV). According to the "Loan Agreements,"
which the Farms frequently did not countersign, these funds were to be used for a Farm's "general
working capital purposes."
f. KWOK and JE misappropriated funds that were raised through the Farm
Loan Program. For example:
i. Approximately $20 million was transferred to Relative-!,
approximately $950,000 of which was used to pay for flight crew services on a private jet;
ii. Approximately $5 million was transferred to an entity owned by
KWOK's spouse;
iii. Approximately $2.3 million was used to cover maintenance
expenses associated with an approximately 145-foot luxury yacht worth approximately $37
million, nominally owned by Relative-2 and used by KWOK; and
iv. Approximately $10 million was transferred to personal bank
accounts in the name of JE and/or JE's spouse.
GICLUBS
14. While making misrepresentations regarding the Farm Loan Program, HO WAN
KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven,"
a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others known
1 All statements attributed herein to KWOK have been translated from Mandarin to English,
unless otherwise noted.
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and unknown, fraudulently induced KWOK's followers to transfer additional funds to a purported
online membership club called GICLUBS. From at least in or about October 2020 through at least
in or about March 2023, KWOK, JE, and others known and unknown, fraudulently obtained more
than approximately $250 million in victim funds through GICLUBS.
a. Starting at least on or about June 20, 2020, in a video distributed via social
media, KWOK promoted and encouraged individuals to purchase what KWOK referred to as a
"G Club ... membership card."
b. Formally launched in or about October 2020, GICLUBS claimed, on its
website, to be "an exclusive, high-end membership program offering a full spectrum of services"
and "a gateway to carefully curated world-class products, services and experiences."
c. To join GICLUBS, a member was required to make a one-time payment to
purchase a "membership," in addition to an annual membership fee. The cost of the membership
varied based on the membership tier selected by the prospective member: Tier 5 Membership cost
$50,000; Tier 4 Membership cost $40,000; Tier 3 Membership cost $30,000; Tier 2 Membership
cost $20,000; and Tier 1 Membership cost $10,000.
d. On or about July 5, 2021, in a video distributed via social media, KWOK
stated, in substance and in part, that there were "25,000 [GICLUBS] member[s] ... $100 million
dollars, the cash [in] the bank account. Then we have the 111 million ... [who] want to join." By
contrast, GICLUBS internal documents reflected approximately 5,900 active members as of in or
about August 2021.
e. In truth and in fact, and as KWOK and JE well knew, GICLUBS provided
nothing close to "a full spectrum of services" and "experiences" to its members. Despite collecting
hundreds of millions of dollars in purported membership fees, GI CLUBS maintained a relatively
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small number of employees and provided its members few to no discernable membership benefits.
Indeed, GICLUBS did not even make good on prizes it offered members for participating in
contests. On or about February 14, 2021, GICLUBS held a webcast and sweepstakes during which
members were promised luxury prizes. On at least one occasion, instead of providing a BMW to
a member who purportedly won a sweepstakes, GIC LUBS claimed to the member that the member
had requested that the value of the BMW be applied toward an upgrade from a Tier 1 GIC LUBS
Membership to a Tier 4 GICLUBS Membership and partially credited toward annual membership
fees for the next three years. As of on or about March 8, 2021-months after GICLUBS launched
and began to collect "membership" fees-GICLUBS did not have a business plan or a board of
directors.
f. KWOK and JE also used GICLUBS as a mechanism to continue fraudulent
private placement offerings. KWOK, and others known and unknown, told KWOK's online
followers that their purchase of GICLUBS memberships would entitle them to stock in KWOK
affiliated entities, such as GTV and GIFashion.
i. In a conversation regarding GICLUBS membership funds on or
about May 4, 2021, JE stated, in substance and in part, that "first of all, [prospective members] are
buying the GICLUBS membership, but they are expecting they would probably receive some
shares, you know, on, on, on the future GTV, I think this is their expectation."
ii. On or about July 30, 2021, KWOK stated in a video distributed via
social media, in substance and in part, "Some of the comrades in arms asked, '[w]ill I still get a
free stock offer when I buy a GICLUBS membership?' 100%. Because I said that I have to promise
that anyone who buys G-Club membership before September 17 must be allotted shares, which is
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exactly the same. Because we said that anyone can choose whether to use your money to buy G
Club before September 17, G-Club and the stock shares. You'll get both."
g. KWOK, JE, and others known and unknown, asked investors to purchase
multiple memberships in GICLUBS, enabling KWOK and JE to increase the amount of money
solicited. In this regard, the GICLUBS website stated, in substance and in part, that members with
multiple memberships would "receive additional benefits" when, in truth and in fact, and as
KWOK and JE well knew, multiple memberships did not provide members with additional
benefits.
15. All told, investors purchased hundreds of millions of dollars' worth of GICLUBS
memberships. However, most of this money did not fund the business of GICLUBS. Rather, HO
WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother
Seven," a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others
known and unknown, misappropriated a substantial portion of the funds victims had paid
GICLUBS for "memberships," using, among other things, a complex web of entities and bank
accounts to do so. For example:
a. GICLUBS funds, which had been funneled through bank accounts in other
entities' names, were used to pay personal expenses for KWOK and his family, including luxury
purchases of an approximately $2.6 million yacht and luxury automobiles that together cost more
than $5 million.
b. In or about November 2021, JE directed approximately $26.5 million of
GICLUBS funds, which had been funneled through bank accounts in other entities' names, toward
the purchase ofKWOK's 50,000 square foot New Jersey mansion.
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c. JE directed the transfer of an additional $13 million of GICLUBS
membership payments to an escrow account. The funds were subsequently used to pay for
extravagant renovations to KWOK's New Jersey mansion, including to a wing for Relative-I and
to a wing for Relative-2, and to purchase various furniture and decorative items including, among
other items, Chinese and Persian rugs worth approximately $978,000, a $62,000 television, and
a $53,000 fireplace log cradle holder.
d. On or about August 5, 2021, JE directed the transfer of approximately $1.1
million consisting of GIC LUBS membership payments into a bank account that JE controlled.
e. GIC LUBS used membership fees to purchase luxury automobiles, including
a custom-built Bugatti sports car for approximately $4.4 million. While the car's signed purchase
agreement listed GICLUBS as the customer, the initial specifications documentation for the
custom-built car named Relative-I as the customer. Relative-I had no official position with
GICLUBS.
The Himalaya Exchange
16. From at least in or about April 2021 through at least in or about March 2023, HO
WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother
Seven," a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others
known and unknown, fraudulently obtained more than approximately $262 million in victim funds
through the Himalaya Exchange, a purported cryptocurrency "ecosystem" accessible on the
internet. The Himalaya Exchange included a purported stablecoin called the Himalaya Dollar
("HDO" or "H Dollar") and a trading coin called Himalaya Coin ("HCN" or "H Coin"). The
Himalaya Exchange claimed that the "stablecoin" was a digital asset with a fixed 1-to-$1 value
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backed by reserves, and that the "trading coin" was a cryptocurrency with valuation based on
supply and demand. JE was the founder and Chairman of the Himalaya Exchange.
17. In videos distributed via social media, HO WAN KWOK, a/k/a "Miles Guo," a/k/a
"Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," the defendant,
trumpeted the prospects and valuation of the Himalaya Exchange and both HCN and HDO, which
he publicly described as cryptocurrencies. For example, in a video posted on the Internet on or
about October 20, 2021, KWOK falsely stated the following, among other things, and in substance
and in part:
a. "I am talking about your H Coins, 'Brother Seven' [i.e., KWOK] designed
it ....[ l]t has the attribute of currency, why? It has 20% gold. Awesome[.] [I]t was born as
currency on the first day, so it has value and it is linked to gold ... clear gold directly. No matter
how much it raises, 20% will tum into gold."
b. "If the H Coin is worthless, [the issuer of H coin] can sell all 20% of the
gold, exchange it to you, and become your money. Or take all the value of 20% gold and ask
everyone to unify it and make it yours."
c. "If anyone loses money, I can say that I will compensate 100%. I give you
100%. Whoever loses money, I will bear it."
d. "I can sell the H Coin in the market in one minute and get it back to my
H Dollar, and back to your fiat money unit. ... [A]nd you can buy anything immediately."
18. The initial coin offering of HCN and HDO occurred on or about November 1, 2021.
HCN began trading at 10 cents and, within approximately two weeks, the Himalaya Exchange
website claimed that each HCN purportedly was worth approximately 27 HDO (i.e., $27), which
represented a 26,900% increase in value. That is, approximately two weeks after the initial coin
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offering, the Himalaya Exchange website indicated that HCN purportedly had an approximately
$27 billion valuation.
19. At the time of the Himalaya Exchange launch, HO WAN KWOK, a/k/a "Miles
Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," the
defendant, marketed HCN to his online followers and others. For example, on or about November
1, 2021-the day of the initial coin offering-KWOK released an official music video for an
original song called "HCoin To the Moon" via social media. The phrase "to the moon" is popularly
associated with cryptocurrencies and implies a sharp increase in value. The music video depicted
KWOK in various luxurious locations and depicted imagery of gold and wealth.
20. At times, including following the Himalaya Exchange launch, KIN MING JE, a/k/a
"William Je," the defendant, misleadingly marketed the Himalaya Exchange. For example, in or
about June 2022, JE attempted to create the impression that a €3,561, 127 purchase of a Ferrari (the
"Ferrari") from a particular auction house was completed with HDO. JE stated, in substance and
in part, that he was "extremely pleased that [a] buyer decided to purchase [a] world-class car using
HDO." Contrary to JE' s claim, the Ferrari was not purchased using HDO. In truth and in fact,
and as JE well knew, a Himalaya Exchange employee sent the auction house an international bank
wire to cover the cost of the Ferrari, while also processing a corresponding "transaction" on the
Himalaya Exchange to create the false appearance that the purchase had taken place using HDO.
JE's statement was also misleading in that, among other things, the unidentified "buyer" of the
Ferrari was, in fact, Relative-I.
21. Contrary to representations of HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles
Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE,
a/k/a "William Je," the defendants, and others known and unknown, HCN and HDO could not be
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traded anywhere other than (purportedly) on the Himalaya Exchange. Moreover, unlike
cryptocurrencies, HCN could not be traded for, or converted into, other currencies. HCN
purportedly could be traded for only HDO (and only on the Himalaya Exchange), and HDO
purportedly only could be converted to or from fiat currency (and only on the Himalaya Exchange).
a. Indeed, the HDO and HCN Whitepapers, available on the Himalaya
Exchange website, provided in fine print that, contrary to KWOK's representations, HCN and
HDO were not cryptocurrencies. Rather, according to the HCN Whitepaper, the "operation of the
Himalaya Exchange and associated applications and infrastructure will be facilitated through the
use of 'Credits."' Those credits (i) could "only be used on the Himalaya Exchange or within the
Himalaya Ecosystem," and (ii) did "not carry any right to require their exchange for fiat currency
or crypto-assets." Moreover, while Himalaya Exchange members could request to exchange their
"HDO" credits for an equivalent payment in U.S. dollars, the HDO Whitepaper stated that the
Himalaya Exchange had the "discretion" to deny any such request.
22. In or about April 2022, HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok,"
a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE, a/k/a
"William Je," the defendants, arranged for the transfer of approximately $37 million in Himalaya
Exchange funds from a Himalaya Exchange bank account to a particular escrow account. The $3 7
million was structured as a purported "loan" to cover the cost of a luxury yacht that KWOK had
previously purchased and used, which yacht was then-owned by an entity held in the name of
Relative-2.
Government Seizure ofF raud Proceeds
23. On or about September 20, 2022 and September 21, 2022, U.S. authorities served
judicially-authorized seizure warrants on several domestic banks, and subsequently seized
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approximately $335 million of proceeds from bank accounts held in the names of Himalaya
Exchange entities and other entities associated with HO WAN KWOK, a/k/a "Miles Guo," a/k/a
"Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING
JE, a/k/a "William Je," the defendants. Following the September 2022 judicially authorized
seizures, JE attempted to transfer approximately $46 million from domestic bank accounts
associated with the Himalaya Exchange, which had not yet been seized by the United States, to a
bank account in the UAE that JE controlled.
a. Within approximately two days of the first judicially authorized seizures of
Himalaya Exchange-related funds, on or about September 22, 2022, JE contacted the management
of a domestic bank that held Himalaya Exchange bank accounts. JE sought to implement a wire
transfer, which he and a Himalaya Exchange executive claimed to the domestic bank was needed
to effectuate a "redemption" from HDO to U.S. dollars for an unnamed "VIP" (i.e., very important
client of the Himalaya Exchange).
b. In subsequent communications with the domestic bank, JE revealed that the
VIP was, in fact, JE himself. JE provided the domestic bank with documents reflecting two
purported HCN sales by JE on or about September 22, 2022-totaling 46 million HDO, which JE
was attempting to "convert" into $46 million. JE twice emphasized to the domestic bank's
management, in substance and in part, that the $46 million transfer needed to happen "today or it
is meaningless."
24. On or about October 16, 2022, pursuant to a judicially authorized warrant, U.S.
authorities seized an additional approximately $274 million of proceeds from several Himalaya
Exchange and GICLUBS accounts at the domestic bank from which JE requested the $46 million
transfer.
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a. As a result of the judicially authorized September and October 2022
seizures, U.S. authorities seized more than approximately $609 million of fraud proceeds,
including approximately $278 million from bank accounts held in the names of the Himalaya
Exchange entities, including accounts that purported to hold its HDO cash reserves.
b. Following the seizures, the Himalaya Exchange website continued to
represent that HDO was backed by a "Reserve consisting of USD and cash-equivalent assets"
when, in truth and in fact, it was not.
c. Despite the seizure of the Himalaya Exchange's cash reserves, the
purported price ofHCN had not suddenly and sharply declined through the date of this Indictment.
STATUTORY ALLEGATIONS
25. From at least in or about 2018 up to and including at least in or about March 2023,
in the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a "Miles Guo," a/k/a
"Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING
JE, a/k/a "William Je," the defendants, and others known and unknown, willfully and knowingly
combined, conspired, confederated, and agreed together and with each other to commit offenses
against the United States, to wit, (1) wire fraud, in violation of Title 18, United States Code, Section
1343; (2) securities fraud, in violation of Title 15, United States Code, Sections 78j(b) & 78ff, and
Title 17, Code of Federal Regulations, Section 240.l0b-5; (3) bank fraud, in violation of Title 18,
United States Code, Section 1344; (4) international promotional money laundering, in violation of
Title 18, United States Code, Section 1956(a)(2)(A); and (5) international concealment money
laundering, in violation of Title 18, United States Code Section 1956(a)(2)(B)(i).
26. It was a part and an object of the conspiracy that HO WAN KWOK, a/k/a "Miles
Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal,"
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and KIN MING JE, a/k/a "William Je," the defendants, and others known and unknown,
knowingly having devised and intending to devise a scheme and artifice to defraud, and for
obtaining money and property by means of false and fraudulent pretenses, representations, and
promises, would and did transmit and cause to be transmitted by means of wire, radio, and
television communication in interstate and foreign commerce, writings, signs, signals, pictures,
and sounds for the purpose of executing such scheme and artifice, in violation of Title 18, United
States Code, Section 1343, to wit, KWOK and JE agreed to obtain victims' money by causing
materially false information and misrepresentations to be transmitted over interstate wires, in
connection with the GTV Private Placement, the Farm Loan Program, GICLUBS, and the
Himalaya Exchange.
27. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a
"Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The
Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others known and
unknown, willfully and knowingly, directly and indirectly, by use of a means and instrumentality
of interstate commerce and of the mails, and of a facility of a national securities exchange, used
and employed, in connection with the purchase and sale of a security registered on a national
securities exchange and any security not so registered, a manipulative and deceptive device and
contrivance, in violation of Title 17, Code of Federal Regulations, Section 240.l0b-5, by
(a) employing a device, scheme and artifice to defraud; (b) making an untrue statement of material
fact and omitting to state a material fact necessary in order to make the statement made, in light of
the circumstances under which it was made, not misleading; and ( c) engaging in an act, practice
and course of business which operated and would operate as a fraud and deceit upon a person, to
wit, KWOK and JE agreed to fraudulently induce investors to participate in the GTV Private
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Placement, the Farm Loan Program, and GICLUBS by providing materially false and misleading
information and representations in connection with purported shares of GTV common stock and
purported companies affiliated with GTV.
28. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a
"Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The
Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others known and
unknown, knowingly would and did execute and attempt to execute a scheme and artifice to
defraud a financial institution, as defined in Title 18, United States Code, Section 20, and to obtain
moneys, funds, credits, assets, securities, and other property owned by, and under the custody and
control of, such a financial institution, by means of false and fraudulent pretenses, representations,
and promises, in violation of Title 18, United States Code, Section 1344, to wit, KWOK and JE
agreed to participate in a scheme to mislead U.S. financial institutions through false and fraudulent
pretenses, representations, and documents, in connection with the GTV Private Placement, the
Farm Loan Program, GICLUBS, and the Himalaya Exchange, in order to obtain money of, or under
the custody and control of, at least one financial institution.
29. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a
"Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The
Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others known and
unknown, would and did transport, transmit, and transfer, and attempt to transport, transmit, and
transfer, a monetary instrument and funds from a place in the United States to and through a place
outside the United States, and to a place in the United States from and through a place outside the
United States, with the intent to promote the carrying on specified unlawful activity, to wit, the
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offenses alleged in Counts Two through Eight of this Indictment in violation of Title 18, United
States Code, Section 1956(a )(2)(A)(i).
30. It was further a part and an object of the conspiracy that HO WAN KWOK, a/k/a
"Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The
Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others known and
unknown, would and did transport, transmit, and transfer, and attempted to transport, transmit, and
transfer, a monetary instrument and funds from a place in the United States to and through a place
outside the United States, and to a place in the United States from and through a place outside the
United States, knowing that the monetary instrument and funds involved in the transportation,
transmission, and transfer represent the proceeds of some form of unlawful activity, and knowing
that such transportation, transmission, and transfer is designed in whole and in part to conceal and
disguise the nature, location, source, ownership, and control of the proceeds of specified unlawful
activity, to wit, the offenses alleged in Counts Two through Eight of this Indictment, in violation
of Title 18, United States Code, Section 1956(a)(2)(B)(i).
Overt Acts
31. In furtherance of the conspiracy and to effect its illegal objects, HO WAN KWOK,
a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The
Principal," and KIN MING JE, a/k/a "William Je," the defendants, and others known and
unknown, committed the following overt acts, among others, in the Southern District of New York
and elsewhere:
a. On or about April 21, 2020, KWOK posted, and caused to be posted, a video
on social media announcing the unregistered offering of GTV stock via the GTV Private
Placement.
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b. On or about June 5, 2020, a co-conspirator not named herein ("CC-1 "),
while located in the Southern District of New York, authorized a wire transfer of $100 million
from Saraca to Fund-1.
c. On or about July 22, 2020, in a video distributed via social media, KWOK
promoted the Farm Loan Program.
d. On or about August 2, 2020, in a video distributed via social media, KWOK
stated, in substance and part, "How much is GTV? ... a market value of 2 billion US dollars."
e. On or about May 28, 2021, JE transferred approximately $13 million from
a bank account in the UAE that JE controlled to a bank account held by an entity (owned by
Relative-2) at a particular bank in New York, New York.
f. On or about July 30, 2021, in a video distributed via social media, KWOK
stated, in substance and in part, "Some of the comrades in arms asked, ' [w ]ill I still get a free stock
offer when I buy a G-Clubs membership?' 100%. Because I said that I have to promise that [to]
anyone who buys G-Clubs membership before September 17 [they] must be allotted shares, which
is exactly the same. Because we said that anyone can choose whether to use your money to buy
G-Clubs before September 17, G-Clubs and the stock shares. You'll get both."
g. On or about August 5, 2021, JE directed the transfer of approximately $1.1
million consisting of funds victims had sent to G[CLUBS in exchange for "memberships" to a
bank account that JE controlled.
h. On or about October 20, 2021, in a video distributed via social media,
KWOK stated, in substance and in part, that KWOK "designed" HCN, that "[n]o matter how much
it raises, 20% will tum into gold," and that "[i]f anyone loses money" on HCN, "I can say that I
will compensate 100%."
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On or about September 22, 2022, JE texted a U.S. bank's management, in
1.
substance and in part, that a $46 million transfer to a JE-controlled bank account in the UAE
needed to happen "today or it is meaningless."
(Title 18, United States Code, Section 371.)
COUNT TWO
(Wire Fraud - GTV Private Placement)
The Grand Jury further charges:
32. The allegations contained m paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
33. From at least in or about April 2020 up to and including at least in or about March
2021, in the Southern District of New York and elsewhere, HOWA N KWOK, a/k/a "Miles Guo,"
a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN
MING JE, a/k/a "William Je," the defendants, knowingly having devised and intending to devise
a scheme and artifice to defraud, and for obtaining money and property by means of false and
fraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by
means of wire, radio, and television communication in interstate and foreign commerce, writings,
signs, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,
KWOK and JE conducted the GTV Private Placement to sell GTV stock and fraudulently obtain
money from victims through false statements and misrepresentations, which scheme was furthered
through electronic communications and monetary transfers to and from the Southern District of
New York and elsewhere.
(Title 18, United States Code, Sections 1343 and 2.)
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•
COUNT THREE
(Securities Fraud - GTV Private Placement)
The Grand Jury further charges:
34. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
35. From at least in or about April 2020 up to and including at least in or about March
2021, in the Southern District ofNew York, and elsewhere, HO WAN KWOK, a/k/a "Miles Guo,"
a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN
MING JE, a/k/a "William Je," the defendants, willfully and knowingly, directly and indirectly, by
use of a means and instrumentality of interstate commerce and of the mails, and of a facility of a
national securities exchange, used and employed, in connection with the purchase and sale of a
security registered on a national securities exchange and any security not so registered, a
manipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal
Regulations, Section 240.1 0b-5, by (a) employing a device, scheme and artifice to defraud;
(b) making an untrue statement of material fact and omitting to state a material fact necessary in
order to make the statement made, in light of the circumstances under which it was made, not
misleading; and ( c) engaging in an act, practice and course of business which operated and would
operate as a fraud and deceit upon a person, to wit, KWOK and JE conducted the GTV Private
Placement to sell GTV stock and obtain money from victims through false statements and
misrepresentations, which scheme was furthered through electronic communications and monetary
transfers to and from the Southern District of New York and elsewhere.
(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal Regulations,
Section 240.l0b-5; and Title 18, United States Code, Section 2.)
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•
COUNT FOUR
(Wire Fraud - Farm Loan Program)
The Grand Jury further charges:
36. The allegations contained m paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
37. From at least in or about June 2020 up to and including at least in or about March
2023, in the Southern District of New York and elsewhere, HOWA N KWOK, a/k/a "Miles Guo,"
a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN
MING JE, a/k/a "William Je," the defendants, knowingly having devised and intending to devise
a scheme and artifice to defraud, and for obtaining money and property by means of false and
fraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by
means of wire, radio, and television communication in interstate and foreign commerce, writings,
signs, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,
KWOK and JE conducted the Farm Loan Program to fraudulently obtain money from victims
through false statements and misrepresentations, which scheme was furthered through electronic
communications and monetary transfers to and from the Southern District of New York and
elsewhere.
(Title 18, United States Code, Sections 1343 and 2.)
COUNT FIVE
(Securities Fraud - Farm Loan Program)
The Grand Jury further charges:
38. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
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..
39. From at least in or about June 2020 up to and including at least in or about March
2023, in the Southern District of New York, and elsewhere, HOWA N KWOK, a/k/a "Miles Guo,"
a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN
MING JE, a/k/a "William Je," the defendants, willfully and knowingly, directly and indirectly, by
use of a means and instrumentality of interstate commerce and of the mails, and of a facility of a
national securities exchange, used and employed, in connection with the purchase and sale of a
security registered on a national securities exchange and any security not so registered, a
manipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal
Regulations, Section 240.l0b-5, by (a) employing a device, scheme and artifice to defraud;
(b) making an untrue statement of material fact and omitting to state a material fact necessary in
order to make the statement made, in light of the circumstances under which it was made, not
misleading; and ( c) engaging in an act, practice and course of business which operated and would
operate as a fraud and deceit upon a person, to wit, KWOK and JE conducted the Farm Loan
Program to obtain money from victims through false statements and misrepresentations, including
regarding, among other things, the value of GTV, which scheme was furthered through electronic
communications and monetary transfers to and from the Southern District of New York and
elsewhere.
(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal Regulations,
Section 240.1 0b-5; and Title 18, United States Code, Section 2.)
COUNT SIX
(Wire Fraud - GICLUBS)
The Grand Jury further charges:
40. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
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41. From at least in or about June 2020 up to and including at least in or about March
2023, in the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a "Miles Guo,"
a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN
MING JE, a/k/a "William Je," the defendants, knowingly having devised and intending to devise
a scheme and artifice to defraud, and for obtaining money and property by means of false and
fraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by
means of wire, radio, and television communication in interstate and foreign commerce, writings,
signs, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,
KWOK and JE promoted and marketed GICLUBS to fraudulently obtain money from victims
through false statements and misrepresentations, which scheme was furthered through electronic
communications and monetary transfers to and from the Southern District of New York and
elsewhere.
(Title 18, United States Code, Sections 1343 and 2.)
COUNT SEVEN
(Securities Fraud - GjCLUBS)
The Grand Jury further charges:
42. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
43. From at least in or about June 2020 up to and including at least in or about March
2021, in the Southern District ofNew York, and elsewhere, HO WAN KWOK, a/k/a "Miles Guo,"
a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN
MING JE, a/k/a "William Je," the defendants, willfully and knowingly, directly and indirectly, by
use of a means and instrumentality of interstate commerce and of the mails, and of a facility of a
national securities exchange, used and employed, in connection with the purchase and sale of a
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security registered on a national securities exchange and any security not so registered, a
manipulative and deceptive device and contrivance, in violation of Title 17, Code of Federal
Regulations, Section 240.lOb-5, by (a) employing a device, scheme and artifice to defraud;
(b) making an untrue statement of material fact and omitting to state a material fact necessary in
order to make the statement made, in light of the circumstances under which it was made, not
misleading; and ( c) engaging in an act, practice and course of business which operated and would
operate as a fraud and deceit upon a person, to wit, KWOK and JE promoted and marketed
GICLUBS to obtain money from victims through false statements and misrepresentations,
including regarding, among other things, the value of GTV, which scheme was furthered through
electronic communications and monetary transfers to and from the Southern District of New York
and elsewhere.
(Title 15, United States Code, Sections 78j(b) & 78ff; Title 17, Code of Federal
Regulations, Section 240. lOb-5; and Title 18, United States Code, Section 2.)
COUNT EIGHT
(Wire Fraud - The Himalaya Exchange)
The Grand Jury further charges:
44. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
45. From at least in or about April 2021 up to and including at least in or about March
2023, in the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a "Miles Guo,"
a/k/a "Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN
MING JE, a/k/a "William Je," the defendants, knowingly having devised and intending to devise
a scheme and artifice to defraud, and for obtaining money and property by means of false and
fraudulent pretenses, representations, and promises, transmitted and caused to be transmitted by
means of wire, radio, and television communication in interstate and foreign commerce, writings,
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signs, signals, pictures, and sounds, for the purpose of executing such scheme and artifice, to wit,
KWOK and JE operated the Himalaya Exchange to fraudulently obtain money from victims
through false statements and misrepresentations, which scheme was furthered through electronic
communications and monetary transfers to and from the Southern District of New York and
elsewhere.
(Title 18, United States Code, Sections 1343 and 2.)
COUNT NINE
(International Promotional Money Laundering)
The Grand Jury further charges:
46. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
47. From at least in or about 2018 up to and including at least in or about March 2023,
in the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a "Miles Guo," a/k/a
"Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING
JE, a/k/a "William Je," the defendants, did transport, transmit, and transfer, and attempt to
transport, transmit, and transfer, a monetary instrument and funds from a place in the United States
to and through a place outside the United States, and to a place in the United States from and
through a place outside the United States, with the intent to promote the carrying on specified
unlawful activity, to wit, KWOK and JE directed and made international transfers of funds into,
out of, and through the United States, with the intent to promote the fraud offenses in Counts Two
through Eight of the Indictment.
(Title 18, United States Code, Sections 1956(a )(2)(A) and 2.)
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COUNT TEN
(International Concealment Money Laundering)
The Grand Jury further charges:
48. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
49. From at least in or about 2018 up to and including at least in or about March 2023,
in the Southern District of New York and elsewhere, HO WAN KWOK, a/k/a "Miles Guo," a/k/a
"Miles Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING
JE, a/k/a "William Je," the defendants, did transport, transmit, and transfer, and attempt to
transport, transmit, and transfer, a monetary instrument and funds from a place in the United States
to and through a place outside the United States, and to a place in the United States from and
through a place outside the United States, knowing that the monetary instrument and funds
involved in the transportation, transmission, and transfer represented the proceeds of some form
of unlawful activity, and knowing that such transportation, transmission, and transfer was designed
in whole and in part to conceal and disguise the nature, location, source, ownership, and control
of the proceeds of specified unlawful activity, namely, the fraud offenses alleged in Counts Two
through Eight of this Indictment, to wit, KWOK and JE conducted international financial
transactions into, and out of, and through the United States involving fraud proceeds, including,
among other transactions, transactions involving bank accounts held in the names of entities
nominally owned by other individuals and by entities not overtly associated with the defendants,
in order to conceal the ownership, control, and/or receipt of the proceeds of the fraud and the illegal
nature and source of such proceeds.
(Title 18, United States Code, Sections 1956(a )(2)(B)(i) and 2.)
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1/f
COUNT ELEVEN
(Unlawful Monetary Transactions)
The Grand Jury further charges:
50. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
51. On or about June 5, 2020, HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles
Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE,
a/k/a "William Je," the defendants, within the United States, knowingly engaged and attempted to
engage in a monetary transaction, as defined in Title 18, United States Code, Section 1957(f)(l),
in criminally derived property of a value greater than $10,000 that was derived from specified
unlawful activity, to wit, KWOK and JE made, and directed others to make, a wire transfer of
approximately $100 million derived from the offenses charged in Counts Two and Three to
Fund-1.
(Title 18, United States Code, Sections 1957 and 2.)
COUNT TWELVE
(Obstruction of Justice)
The Grand Jury further charges:
52. The allegations contained in paragraphs 1 through 24 of this Indictment are
repeated and realleged as if fully set forth herein.
53. From at least on or about September 20, 2022 through the date of the filing of this
Indictment, in the Southern District of New York and elsewhere, KIN MING JE, a/k/a "William
Je," the defendant, corruptly obstructed, influenced, and impeded an official proceeding and
attempted so to do, to wit, JE attempted to transfer money to the UAE, beyond the jurisdiction of
the United States, to impede and interfere with a federal grand jury investigation in the Southern
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District ofNew York of the offenses alleged in Counts One through Eleven of this Indictment, and
proceedings before the United States District Court for the Southern District of New York
concerning the seizure and forfeiture of criminally derived proceeds.
(Title 18, United States Code, Sections 1512(c)(2) and 2.)
FORFEITURE ALLEGATIONS
54. As a result of committing the offenses alleged in Counts One through Eight of this
Indictment, HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles Kwok," a/k/a "Guo Wengui,"
a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE, a/k/a "William Je," the
defendants, shall forfeit to the United States, pursuant to Title 18, United States Code, Section
981(a)(l)(C) and Title 28 United States Code, Section 2461(c), any and all property, real and
personal, that constitutes or is derived from proceeds traceable to the commission of said offenses,
including but not limited to a sum of money in United States currency representing the amount of
proceeds traceable to the commission of said offenses and, and the following specific property:
a. $64,826.87 in United States currency formerly on deposit in Account
Number 5090037713 at Silvergate Bank held in the name of "Hamilton Opportunity Fund SPC,"
seized by the Government on or about September 18, 2022;
b. $75,000,000.00 in United States currency formerly on deposit in Account
Number 5090037705 at Silvergate Bank held in the name of "Hamilton Opportunity Fund SPC,"
seized by the Government on or about September 18, 2022;
c. $467,343.00 in United States currency formerly on deposit in Account
Number 5090037754 at Silvergate Bank held in the name of "Hamilton Opportunity Fund SPC,"
seized by the Government on or about September 18, 2022;
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•
d. $89,992,861.75 in United States currency formerly on deposit in Account
Number 5090042770 at Silvergate Bank held in the name of "Hamilton Opportunity Fund SPC,"
seized by the Government on or about September 18, 2022;
e. $1,683,077.40 in United States currency formerly on deposit in Account
Number 5090042762 at Silvergate Bank held in the name of "Hamilton Opportunity Fund SPC,"
seized by the Government on or about September 18, 2022;
f. $85,899,889.20 in United States currency formerly on deposit in Account
Number 5090042853 at Silvergate Bank held in the name of"Hamilton Opportunity Funds SPC,"
seized by the Government on or about September 18, 2022;
g. $48,230,709.62 in United States currency formerly on deposit in Account
Number 5090030288 at Silvergate Bank held in the name of"Hamilton Investment Management"
Ltd., seized by the Government on or about September 18, 2022;
h. $1,800,000.00 in United States currency formerly on deposit in Account
Number 5090037739 at Silvergate Bank held in the name of "Hamilton Opportunity Fund SPC,"
seized by the Government on or about September 18, 2022;
i. $85,899,889.20 in United States currency formerly on deposit in Account
Number 5090042853 at Silvergate Bank held in the name of"Hamilton Opportunity Funds SPC,"
seized by the Government on or about September 18, 2022;
j. $4,643,744.70 in United States currency formerly on deposit in Account
Number 7801000590 at FV Bank held in the name of "Himalaya International Reserves, Ltd.,"
seized by the Government on or about September 20, 2022;
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..
(
k. $14,599,257.25 in United States currency formerly on deposit in Account
Number 7801000254 at FV Bank held in the name of "Himalaya International Clearing, Ltd.,"
seized by the Government on or about September 20, 2022;
I. $11,538,579.87 in United States currency formerly on deposit in Account
Number MBil O1 03-0000 at Mercantile Bank International held in the name of "G Club
International Ltd.," seized by the Government on or about October 16, 2022;
m. $9,451,170.54 in United States currency formerly on deposit in Account
Number MBI10133-0000 at Mercantile Bank International held in the name of "Himalaya
International Clearing Ltd.," seized by the Government on or about October 16, 2022;
n. $2,823,642.39 in United States currency formerly on deposit in Account
Number MBI10137-0000 at Mercantile Bank International held in the name of"Hamilton Capital
Holding Ltd.," seized by the Government on or about October 16, 2022;
o. $249,000,115.46 in United States currency formerly on deposit in Account
Number MBI10138-0000 at Mercantile Bank International held in the name of "Himalaya
International Reserves Ltd.," seized by the Government on or about October 16, 2022;
p. $283,965.11 in United States currency formerly on deposit in Account
Number MBI10139-0000 at Mercantile Bank International held in the name of "Himalaya
International Financial Group Ltd.," seized by the Government on or about October 16, 2022;
q. $1,085,623.67 in United States currency formerly on deposit in Account
Number MBil O1 71-0000 at Mercantile Bank International held in the name of "Hamilton
Investment Management Ltd.," seized by the Government on or about October 16, 2022;
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...
◄
r. $43,782.71 in United States currency formerly on deposit in Account
Number MBil0l 72-0000 at Mercantile Bank International held in the name of "G Fashion
International Limited," seized by the Government on or about October 16, 2022;
s. $161,809.47 in United States currency formerly on deposit in Account
Number MBil 0 183-0000 at Mercantile Bank International held in the name of "Himalaya
Currency Clearing Pty Ltd.," seized by the Government on or about October 16, 2022;
t. $2,745,377.75 in United States currency formerly on deposit in Account
Number 9878904409 at Manufacturers & Traders Trust Co. held in the name of "GETTR USA,
Inc.," seized by the Government on or about September 18, 2022;
u. $9,899,659.19 in United States currency formerly on deposit in Account
Number 157525208185 at US Bank held in the name of "G Fashion," seized by the Government
on or about September 18, 2022;
v. All that lot or parcel of land, together with its buildings, appurtenances,
improvements, fixtures, attachments, and easements, located at 675 Ramapo Valley Road,
Mahwah, New Jersey 07430, Parcel No.3300021-03-00001-02 and described as Lot Number: 1.02
Block: 21.03 District: 33 City, Municipality, Township: MAHWAH TWP
w. A Bugatti Chiron Super Sport, bearing Vehicle Identification Number
VF9SW3V3XNM795047;
x. A Lamborghini Aventador SVJ Roads, bearing Vehicle Identification
Number ZHWUN6ZD2MLA10393;
y. A Rolls Royce Phantom EWB, bearing Vehicle Identification Number
SCAT T8C08MU206445;
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J
z. A 46m 2014 Feadship superyacht "Lady May" (ex Como), bearing IMO
Number 112359, MMSI Number 319059500, and Callsign ZGDQ9;
aa. A Besendorfer 185VC Porsche #49539 piano with custom bench, purchased
for approximately $140,938.69;
bb. A Railis Design Iceland Contemporary Poseidon Bed with Nightstands,
Ebony Veneer, Brass, Velvet, purchased for approximately $31,413.71;
cc. A Hastens 2000T md mattress, purchased for approximately $36,590.00;
dd. A Hastens 2000T sf mattress, purchased for approximately $36,210.00;
ee. A Wembe watch storage box, purchased for approximately $59,392.91;
ff. A Samsung Q900 Series QN98Q900RBF 98" QLED Smart TV - 8K,
purchased for approximately $62,787.54;
gg. A Louis XV Style French Ormolu-Mounted Mahogany Commode by
Joseph Emmanuel Zweiner;
hh. A "K'ang Hsi" extension table in etched and patinated pewter and bronze
with hand-painted enamel colors by Philip & Kelvin LaV erne, purchased for approximately
$180,000.00; and
ii. A "Punto '83" table in stainless steel with mesh tabletop with adjustable
height and adjustable petals by Gabriella Crespi, Italy 1982, purchased for approximately
$180,000.00.
(a) through (ii), collectively, the "Specific Property."
55. As a result of committing the money laundering offenses alleged in Counts One,
Nine, Ten and Eleven of this Indictment, HO WAN KWOK, a/k/a "Miles Guo," a/k/a "Miles
Kwok," a/k/a "Guo Wengui," a/k/a "Brother Seven," a/k/a "The Principal," and KIN MING JE,
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a/k/a "William Je," the defendants, shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 982(a)(l), any and all property, real and personal, involved in said offense,
or any property traceable to such property, including but not limited to a sum of money in United
States currency representing the amount of property involved in said offense and the Specific
Property.
Substitute Assets Provision
56. If any of the above-described forfeitable property, as a result of any act or omission
of the defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third person;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be subdivided
without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and
Title 28, United States Code, Section 2461 ( c) , to seek forfeiture of any other property of the
defendants up to the value of the above forfeitable property.
(Title 18, United States Code, Sections 981 and 982;
Title 21, United States Code, Section 853; and
Title 28, United States Code, Section 2461.)
~~
~~
FORE N DAMIAN WILLIAMS
3/
i.R(c2vEJ3 United States Attorney
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