郭文贵刑事案 · ECF #716-6

Exhibit F

UNITED STATES DISTRICT COURT 23 MAG 3908 SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA TO BE FILED UNDER SEAL -v.- Affidavit in Support of Seizure All monies, funds, and assets contained in the Warrant TD Bank, N.A. official check account that were previously held in TD Bank, N.A. accounts 440- Pursuant to 18 U.S.C. §§ 981 and 984 5491468 and 440-5492044, held by G CLUB OPERATIONS LLC (the “Target Account”), and all funds traceable thereto, including accrued interest (the “Target Property”); Defendant-in-rem. SOUTHERN DISTRICT OF NEW YORK) ss.: Zachary Effting, Special Agent, Federal Bureau of Investigation, being duly sworn, deposes and says: I. Introduction 1. I am a Special Agent with the Federal Bureau of Investigation (“FBI” or “Investigating Agency”). I have been a Special Agent with the FBI since in or about February 2020. Since in or about October 2020, I have been assigned to the FBI’s Complex Financial Crimes squad. During my time with the FBI, I have participated in investigations of securities and wire fraud schemes, bank fraud, and money laundering, and have, among other things, conducted or participated in debriefings of witnesses, reviews of financial records, and the execution of search warrants. In particular, I have participated in the execution of search warrants involving physical premises, property used in connection with crime, electronic devices, and other electronic evidence. 2. This affidavit is submitted in support of the United States of America’s Application for the issuance of a seizure warrant, pursuant to 18 U.S.C. §§ 981 and 984, to seize the following

property: all monies, funds, and assets contained in the TD Bank, N.A. official check account that were previously held in TD Bank, N.A. accounts 440-5491468 and 440-5492044, held by G CLUB OPERATIONS LLC (the “Target Property”). 3. The Target Property constitutes the proceeds of violations of 18 U.S.C. §§ 1343 (wire fraud); 1344 (bank fraud); and 1956 (money laundering and conspiracy to commit money laundering) (together, the “Target Offenses”), as described below. 4. This affidavit is based on, among other sources of information: (i) my review of documents and other evidence; (ii) my conversations with other law enforcement personnel and review of law enforcement reports, including reports of surveillance; (iii) my review of publicly available information, including digital videos posted on the Internet and other open source research conducted on the Internet relating to, among other ventures, “G|CLUBS”; (iv) my participation and the participation of other law enforcement officers in various witness interviews; (v)my review of evidence obtained pursuant to subpoenas, orders issued pursuant to 18 U.S.C. §2703(d) for non-content information, and judicially authorized search warrants, including emails, cellphone location data, and cellphone toll records; (vi) my review and analysis of various bank account records; and (vii) my training and experience concerning the commission of financial crimes. Because this affidavit is being submitted for the limited purpose of establishing probable cause, it does not include all the facts that I have learned during the course of my investigation. Where dates, figures, and calculations are set forth herein, they are approximate. Where the contents of documents and the actions, statements, and conversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated. 5. As set forth below, there is probable cause to believe that the Target Property is subject to seizure and forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A) and (C) and 18 U.S.C. §981(b) as property involved in violations of 18 U.S.C. § 1956 and § 1957, and/or the proceeds 2

of violations of 18 U.S.C. § 1343 , or property traceable thereto. In summary, the evidence reveals a fraudulent scheme (the “Fraud”) that pertains to several interrelated companies and their affiliated entities, including GTV Media Group Inc., G Fashion (“G Fashion”), the Himalaya Farm Alliance (the “Farms”), Himalaya International Clearing Ltd. (“Himalaya International Clearing”), G Club Operations LLC (“G Club”), Hamilton Investment Management Ltd. (“Hamilton”), ACA Capital Group Ltd. (“ACA Capital”), and Crane Advisory Group LLC (“Crane”). As set forth in more detail below, the leaders of the Fraud are Miles Guo, a/k/a “Guo Wengui,” a/k/a “Miles Kwok” (“GUO”) and William Je, a/k/a Je Kin Ming (“JE”). 6. Forensic accountants and analysts at the FBI and SEC and I have traced the flow of certain fraud proceeds from victims of the fraud scheme to the purchase of the Target Property. II. Statutory Basis for Forfeiture 7. The statutory provisions pursuant to which the Target Property is subject to civil seizure and forfeiture are as follows: Money Laundering Offenses 8. Title 18, United States Code, Section 981(a)(1)(A), subjects to civil forfeiture: Any property, real or personal, involved in a transaction or attempted transaction in violation of section 1956, 1957 or 1960 of this title, or any property traceable to such property. 9. 18 U.S.C. § 1956(a)(2)(A) provides that any person who: transports, transmits, or transfers, or attempts to transport, transmit, or transfer a monetary instrument or funds from a place in the United States to or through a place outside the United States or to a place in the United States from or through a place outside the United States— (A) with the intent to promote the carrying on or specified unlawful activity— [shall be guilty of a crime.] 3

10. 18 U.S.C. § 1956(a)(2)(B)(i) provides that any person who: transports, transmits, or transfers, or attempts to transport, transmit, or transfer a monetary instrument or funds from a place in the United States to or through a place outside the United States or to a place in the United States from or through a place outside the United States— (B) knowing that the monetary instrument or funds involved in the transportation, transmission, or transfer represent the proceeds of some form of unlawful activity and knowing that such transportation, transmission, or transfer is designed in whole or in part— (i) to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity [shall be guilty of a crime.] 11. 18 U.S.C. § 1957 provides that any person who knowingly engages or attempts to engage in a monetary transaction in criminally derived property of a value greater than $10,000 and is derived from specified unlawful activity [shall be guilty of a crime.] 12. 18 U.S.C. § 1956(h) further provides that “[a]ny person who conspires to commit any offense defined in [Sections 1956 and 1957] shall be subject to the same penalties as those prescribed for the offense the commission of which was the object of the conspiracy.” Wire Fraud Offenses 13. For purposes of Section 1956, “specified unlawful activity,” defined in 18 U.S.C. § 1956(c)(7), includes, among other things, violations of 18 U.S.C. § 1343, as well as conspiracy to commit violations thereof. See 18 U.S.C. §§ 1956(c)(7) and 1961(1). 14. Title 18, United States Code, Section 981(a)(1)(C), subjects to civil forfeiture any property, real or personal, which constitutes or is derived from proceeds traceable to a violation of . . . any offense constituting ‘specified unlawful activity’ (as defined in section 1956(c)(7) of this title), or a conspiracy to commit such offense.” 4

Seizure Warrants 15. The Court is empowered by 18 U.S.C. § 981(b) to issue a seizure warrant for any property subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A) & (C). Section 981(b)(2) provides that such a seizure may be made “pursuant to a warrant obtained in the same manner as provided for a search warrant under the Federal Rules of Criminal Procedure.” In addition, Section 981(b)(3) provides that, notwithstanding the provisions of Federal Rule of Criminal Procedure 41(a), a seizure warrant may be issued pursuant to Section 981(b) by a judicial officer in any district in which a forfeiture action against the property may be filed under Title 28, United States Code, Section 1355(b). Under Section 1355(b)(1)(A), a forfeiture action or proceeding may be brought in the district in which any of the acts or omissions giving rise to the forfeiture occurred. As set forth below, the offenses underlying the requested seizure warrant included acts or omissions occurring in the Southern District of New York. III. Probable Cause A. Background Indictments 16. On March 30, 2023, the Government filed a 12-count superseding Indictment, captioned United States v. Ho Wan Kwok, Kin Ming Je, and Yanping Wang, S1 23 Cr. 118 (the “Indictment”), charging 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” (“KWOK”), Kin Ming Je, a/k/a “William Je” (“JE”), and Yanping Wang, a/k/a “Yvette” (“WANG”) with violations of 18 U.S.C. §§ 371 (conspiracy to commit wire, bank and securities fraud and money laundering), 1343 (wire fraud), 1957 (unlawful monetary transactions), and 2 (aiding and abetting). The Indictment also charged KWOK and JE with violations of 18 U.S.C. §§ 1956(a)(2)(A) (international concealment money laundering) and 1956(a)(2)(B)(i) (international promotional money laundering); and 15 U.S.C. 5

§§ 78j(b) & 78ff and 17 C.F.R. § 240.10b-5 (securities fraud). In addition, the Indictment charged JE with a violation of 18 U.S.C. § 1512(c)(2) (obstruction of justice). The Indictment is attached hereto as Exhibit 1 and is incorporated by reference herein. Overview of the Investigation 17. Since in or around May 2020, the United States Attorney’s Office for the Southern District of New York (“SDNY”) and the FBI, among other law enforcement agencies, have been investigating a fraud (the “Fraud”) that pertains to several companies that are owned or operated by, or otherwise affiliated with, KWOK, JE, WANG, and other Target Subjects. To date, the investigation has revealed that the Fraud involved the solicitation of more than $1 billion and the subsequent money laundering and/or misappropriation of hundreds of millions of dollars. KWOK is the leader of, and directed, the Fraud. JE is the financial architect and key money launderer for the Fraud. WANG operated as KWOK’s “chief of staff” and managed the day-to-day operations of the entities used to perpetrate the Fraud. 18. KWOK, JE, and WANG have conducted the Fraud, which occurred between at least in or about 2018 through in or about March 2023, through various interrelated offerings, all of which exhibit features that are consistent with fraud. For example, as described further below and in the Indictment, investors were promised unrealistic, outsized returns on their investments; investors were induced to invest on the basis of numerous misrepresentations; a large portion of the investment money was misappropriated; and with respect to the sale of digital asset securities, those currencies have never been tradable on a public exchange, despite representations that they would be. 19. Based on my conversations with other law enforcement officers who have participated in this investigation and my review of the Indictment, I have learned that the Fraud includes, among other means and methods, the following: 6

a. Starting at least in or about June 2020, KWOK began promoting G|CLUBS, a purported high-end membership club. G|CLUBS, which launched in or about October 2020, claimed to provide “Membership Concierge services with exclusive offers and discounts for luxury hotels and retailers for High Net Worth individuals from the Asian market” through the sale of purported memberships. In soliciting G|CLUBS membership funds, KWOK and others represented that G|CLUBS membership would be a mechanism to obtain stock in KWOK- affiliated companies, including GTV and a company called G|FASHION. G|CLUBS raised at least approximately $250 million in purported membership fees, which funds were commingled with other fraud proceeds and used to promote the Fraud and/or misappropriated. See Ex. 1 at ¶¶ 14-15. 20. Based on my training and experience and my conversations with other law enforcement officers who have participated in this investigation, I am aware that each of these means and methods of the Fraud described more fully in the Indictment bear the hallmarks of fraud. For example, the investors were promised unrealistic outsized returns on their investments; investors were induced to invest on the basis of numerous misrepresentations; and more than approximately $300 million in fraud proceeds has been misappropriated, including an approximately $100 million investment in a high-risk hedge fund for the benefit of KWOK’s son, the purchase of a mansion in Mahwah, New Jersey for approximately $26.5 million in or about December 2021 through an entity owned and controlled by JE on behalf of KWOK, and the transfer of approximately $13 million in fraud proceeds to an escrow account, which funds were subsequently used to pay for extravagant renovations to, and furnishings for, the Mahwah Mansion. See Ex. 1 at ¶¶ 12(h), 13(f), 15. 7

Financial Investigation of Fraud Proceeds 21. Based on my conversations with other law enforcement officers and my training and experience, I am aware that financial tracing analysis conducted by the United States Attorney’s Office for the Southern District of New York (USAO-SDNY), the FBI, and the SEC (which is engaged in a parallel investigation) uncovered extensive layering of Fraud funds through more than 500 accounts at financial institutions, held in the names of more than 80 individuals or entities, including various of the KWOK-controlled entities and dozens of other affiliated entities that KWOK, JE, WANG, and other Target Subjects appear to have established as money laundering vehicles. As the examples described in part in paragraphs 22-24, infra, show, financial tracing identified large transfers of Fraud proceeds to, through, and among domestic and international bank accounts, including accounts that JE controlled in the UAE and the Bahamas, consistent with a large-scale layering of proceeds of crime for purposes of concealing their source, origin, location, and/or nature. See, e.g. Ex. 1 at ¶¶ 3, 4, 32, 32(g). Tracing of Fraud Scheme Proceeds 22. Based on my participation in this investigation, training, experience, review and analysis of various bank account records and financial analyses performed by me and financial analysts at the FBI and SEC, open-source research that I have conducted on the Internet, my review of evidence obtained pursuant to subpoenas and judicially authorized search warrants, and my conversations with others, I have learned the following, among other things: a. Investors participated in the Fraud by either wiring money directly to a bank account controlled or used by entities affiliated with KWOK, JE, and others (including the Farms, G|CLUBS, or the Himalaya Exchange), or by wiring or otherwise transferring money to other entities at the direction of the Target Subjects (including, for example, a company called Crane Advisory Group (“Crane”), which funds are then transmitted to bank accounts ultimately 8

controlled by KWOK, JE, and their associates). I am aware of accounts located in the UAE, the United Kingdom, the United States, the Bahamas, and the British Virgin Islands, which KWOK, JE, and other Target Subjects have used for the purpose of receiving investment funds from investors in the Fraud, including G|CLUBS investors. b. For example, between in or about May 2021 and June 2021, approximately $100 million in Fraud funds were transferred from G|CLUBS bank accounts into a Bahamas bank account held in the name of Hamilton Capital Management Ltd. (the “Hamilton Bahamas Account”), which is a JE-controlled company. Before the approximately $100 million of Fraud funds was combined in the Hamilton Bahamas Account, they were layered through a series of entities at various different banks in a manner that, based on my training and experience, is indicative of money laundering. Specifically: i. Certain prospective investors were instructed to send funds intended as an investment in GTV (for example) to bank accounts in the name of Crane. Approximately $78.2 million of Fraud funds was sent from individual or institutional investors in China and elsewhere to two Crane bank accounts (the “Crane Citibank Accounts”) between in or about November 2020 and April 2021. ii. Approximately $60 million of those Fraud funds were then transferred from the Crane Citibank Accounts to approximately five different bank accounts at Morgan Stanley Smith Barney (“MSSB”) held in the name of Crane (together, the “Crane MSSB Accounts”). iii. The approximately $60 million in Fraud funds from the Crane MSSB Accounts was combined with approximately $49 million in other Fraud funds that had been transferred into the Crane MSSB Accounts from two Crane accounts at a different bank, Capital 9

One (together, the “Crane Capital One Accounts”), raising the total combined balance in the Crane MSSB Accounts to approximately $109 million. iv. Approximately $79 million of those approximately $109 million in Fraud funds in the Crane MSSB Accounts were then transferred to accounts at the same bank (i.e., MSSB), but in the name of G|CLUBS (i.e., the G|CLUBS MSSB Accounts). The approximately $79 million was combined with approximately $79.7 million in other Fraud funds that had been transferred into the G|CLUBS MSSB Accounts from individual G|CLUBS investors and from G|CLUBS bank accounts at Signature Bank, First Bank of Puerto Rico, and City National Bank, raising the total combined balance of Fraud funds in the G|CLUBS MSSB Accounts to more than approximately $158 million. v. Between in and about October 2021 and in or about April 2022, approximately $85 million of Fraud funds was transferred from the G|CLUBS MSSB Accounts to the Hamilton Bahamas Account, and combined with approximately $15 million in other Fraud funds (relating to G|CLUBS and the Himalaya Exchange). Thus, the $100 million of Fraud funds in the Hamilton Bahamas Account consisted exclusively of funds transferred from the G|CLUBS MSSB Accounts and other accounts containing Fraud funds. 23. Between in or about September 2022 and March 2023, law enforcement served judicially authorized seizure warrants on several U.S. banks for the funds located in approximately 21 additional bank accounts, into which I and forensic accountants and analysts at the FBI and SEC traced proceeds of the Fraud. The bank accounts subject to seizure were held in the names of various entities associated with KWOK and JE, or entities under JE’s control, including G|CLUBS, G|Fashion, and the Hamilton entities that control the Himalaya Exchange. Between in or about September 2022 and March 2023, the Government seized approximately $630 million in fraud proceeds pursuant to the seizure warrants, including approximately $11,538,579.87 from a 10

G|CLUBS account at Mercantile Bank (the “G|CLUBS Mercantile Account”), which represented the balance in the account at the time of seizure. See Ex. 1 at ¶¶ 23-24. 24. Based on my participation in this investigation, training, experience, review and analysis of various bank account records and financial analyses performed by me and forensic accountants and analysts at the FBI and SEC, my review of court filings and evidence obtained pursuant to subpoenas and judicially authorized search warrants, and my conversations with others, I have learned the following, among other things: a. On or about May 5, 2021, a business bank account application was submitted to Mercantile Bank for the G|CLUBS Mercantile Account. The application for the G|CLUBS Mercantile Account described G|CLUBS’s business as, in substance and in part, “holding the securities of (or other equity interests in) companies and enterprises.” b. Alex Hadjicharalambous, the Financial Controller for G|CLUBS, was an authorized signer on the G|CLUBS Mercantile Account. c. Proceeds of the Fraud were traced into G|CLUBS Mercantile Account. For example: i. The initial deposit of funds into G|CLUBS Mercantile Account, which occurred on or about July 2, 2021, consisted of an approximately $4 million transfer of traceable Fraud proceeds from a G|CLUBS account held at Medici Bank. ii. Between on or about August 23, 2021 and November 19, 2021, approximately $74 million of Fraud proceeds was transferred from the G|CLUBS MSSB Accounts into the G|CLUBS Mercantile Account. iii. On or about December 24, 2021, approximately $10 million of Fraud proceeds was transferred from a Silvergate Bank account ending in -7739, held in the name 11

of Hamilton Opportunity Fund SPC (which account was seized pursuant to one of the Government’s prior seizure warrants) to the G|CLUBS Mercantile Account. The Target Property 25. Based on my review of documents, subpoena and search warrant returns, law enforcement reports, my conversations with witnesses and other law enforcement officers, and my training and experience, I am aware of the following, among other things: a. Subpoena returns provided by TD Bank, N.A. reflect that “G Club Operations LLC” opened two bank accounts at TD Bank on or about January 13, 2022— specifically, a business premier checking account ending in -1468 (the “1468 Account”) and a business simple checking account ending in -2044 (the “2044 Account,” and together with the 1468 Account, the “TD Accounts”). b. In account opening documentation dated on or about January 13, 2022, Limarie Reyes Molinaris (“Reyes Molinaris”), the then-CEO for G|CLUBS, is listed as the sole authorized signer for the TD Accounts. On or about February 1, 2022, the signature card for each of the TD Accounts was updated to add Alex Hadjicharalambous, the Financial Controller for G|CLUBS, as an additional authorized signer. See supra at ¶ 24(b). c. On or about January 14, 2022, Reyes Molinaris deposited a “Manager’s Check” from Oriental Bank in Puerto Rico into the 1468 Account; the check was in the amount of approximately $2,931,953.17, was dated November 22, 2021, was made payable to G CLUB OPERATIONS LLC. Based on my participation in this investigation and my review of documents, I am aware that the Oriental Bank check represented the balance of a G|CLUBS account that Oriental Bank had closed, which account held funds traceable to the Fraud, that is, funds derived from the fraudulent solicitation of investments. Based on my review of records for the 1468 Account, I am aware that only approximately 21 disbursements were made from the 1468 12

Account, and I am further aware that those disbursements consisted primarily of wire / ACH fees and check card purchases amounting to less than approximately $128,000 in debits. d. On or about January 14, 2022, approximately 13 checks were deposited into the 2044 Account, for a collective deposit of approximately $313,600.00. The 13 checks were made payable to G CLUB OPERATIONS LLC and were dated between on or about July 15, 2021 and on or about August 3, 2021. Based on my review of documents, including G|CLUBS membership lists and the memo lines of the checks, it appears that the checks were from G|CLUBS investors who were fraudulently induced to invest money. Between in or about January 2022 and July 2022, the 2044 Account received approximately $15,707,658.67 in credits (consisting of deposits from G|CLUBS investors who were fraudulently induced to invest money) and approximately $9,637,000.17 in debits (including two outgoing wires to a particular bank account at Kyrgyz-Swiss Bank in Kyrgyzstan totaling approximately $7,000,000). e. TD Bank closed the TD Accounts on or about March 7, 2023. i. The 1468 Account statement for the period March 1, 2023 through March 7, 2023 reflects a closing balance of approximately $2,815,502.30. On or about March 7, 2023, TD Bank issued a check to G CLUB OPERATIONS LCC (numbered 90519810-6) for the closing balance of the 1468 Account. ii. The 2044 Account statement for the period March 1, 2023 through March 7, 2023 reflects a closing balance of approximately $4,357,924.95. On or about March 7, 2023, TD Bank issued a check to G CLUB OPERATIONS LCC (numbered 90519811-7) for the closing balance of the 2044 Account. f. Based on my participation in this investigation, my review of documents, and my conversations with others, I am aware that the combined approximately $7,173,427.25 that represents the closing balances of the TD Accounts is currently being held in the Target Account 13

(i.e., the TD Bank, N.A. official check account that is holding funds previously held in TD Bank, N.A. accounts 440-5491468 and 440-5492044, held by G CLUB OPERATIONS LLC). IV. Conclusion 26. Based on the foregoing, I submit that there is probable cause to believe that the funds held in the Target Property are subject to forfeiture as proceeds of violations of 18 U.S.C. §1343 (wire fraud), and/or as property involved in violations of 18 U.S.C. §§ 1956(a)(2)(A)(i), 1956(a)(2)(B)(i), 1957, and 1956(h) (money laundering and conspiracy to commit money laundering). 27. Accordingly, pursuant to 18 U.S.C. § 981(b), I respectfully request that the Court issue a warrant authorizing the seizure of the Target Property. _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_)__ ZACHARY EFFTING Special Agent Federal Bureau of Investigation Sworn to me through the transmission of this Affidavit by reliable electronic means, pursuant to Federal Rules of Criminal Procedure 41(d)(3) and 4.1, this _1_2 day of May, 2023 _____________________________________ THE HONORABLE VALERIE FIGUEREDO UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK 14

Ex. 1

CaseC 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 UNITED STATES DISTRICT COURT ORIGINAL 1 SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA INDICTMENT V. Sl 23 Cr. 118 (AT) 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, a/k/a "William Je," and YANPING WANG, a/k/a "Yvette," 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," KIN MING JE, a/k/a "William Je," and Y ANPING WANG, a/k/a "Yvette," 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, WANG, and their co-conspirators operated through a series of complex fraudulent and fictitious businesses and investment opportunities that connected dozens of interrelated

CaseC 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 entities, which allowed the defendants and their co-conspirators to solicit, launder, and misappropriate victim funds. 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," KIN MING JE, a/k/a "William Je," and YANPING WANG, a/k/a "Yvette," 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, JE, and WANG well knew, the entities were instrumentalities that KWOK, JE, and WANG created and used to perpetrate their fraud and exploit KWOK's followers. The scheme allowed KWOK, JE, and WANG 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," KIN MING JE, a/k/a "William Je," and YANPING WANG, a/k/a "Yvette," the defendants, and their co-conspirators, laundered hundreds of millions of dollars of fraud proceeds. To conceal the illegal source of the funds, KWOK, JE, and WANG 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. 2

CaseC 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 'v 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 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 ofKWOK'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," KIN MING JE, a/k/a "William Je," and YA NPING WANG, a/k/a "Yvette," the defendants, and their co-conspirators, operated the scheme for years, and continued to do so at least through at least March 2023. 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. 3

CaseC 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 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, 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. 4

CaseC 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 8. At all relevant times, Y ANPING WANG, a/k/a "Yvette," the defendant, was a citizen of China who principally resided in New York, New York and has had a close relationship 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," the defendant. In particular, WANG has worked for KWOK and KWOK's family for several years, since at least in or about 2018, and has operated as a "chief of staff' for KWOK. In that capacity, WANG has held titles in a variety of entities that were instrumentalities of the fraud described herein. For example, WANG has served as the President, Treasurer, and Secretary of entities that purportedly managed KWOK's money. 9. 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. 10. 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, likewise held no formal position or title at GTV, but in fact exercised control over its finances. Saraca was the parent company of GTV. YANPING WANG, a/k/a "Yvette," the defendant, was an "Executive Director" of GTV. 11. At certain times relevant to this Indictment, G Club Operations, LLC ("GICLUBS") _was a purported membership organization based in Puerto Rico and in New York, New York. GICLUBS 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 GICLUBS. KIN MING JE, a/k/a "William Je," 5

CaseC 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 the defendant, likewise held no formal position or title at GICLUBS, but in fact exercised control over its finances. . 12. 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 GICLUBS and GIFashion, 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 13. Between in or about April 2020 and in or about June 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," KIN MING JE, a/k/a "William Je," and YA NPING WANG, a/k/a "Yvette," the defendants, and others known and 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 6

CaseC 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 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. Y ANPING WANG, a/k/a "Yvette," the defendant, was identified in the PPM as an "Executive Director" of 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;" ii. GTV planned to use the proceeds raised from the GTV Private Placement "to expand and strengthen the business;" and The PPM included a chart itemizing the "contemplated use of 111. proceeds" raised from the GTV Private Placement: 7

CaseC 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 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 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 8

CaseC 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 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," KIN MING JE, a/k/a "William Je," and YANPING WANG, a/k/a "Yvette," 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-I") 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-I 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-I did not own any shares of Saraca. Ultimately, the investment into Fund-I lost approximately $30 million in value. i. After directing $100 million of GTV victim funds into Fund-I, 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 14. 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 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 9

CasCea 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 $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 (e ach 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 of large 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 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. 1 All statements attributed herein to KWOK have been translated from Mandarin to English, unless otherwise noted. 10

CasCea 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 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-I, 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 15. 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 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 11

CasCea 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 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, GICLUBS maintained a relatively small number of employees and provided its members few to no discemable membership benefits. Indeed, GICLUBS did not even make good on prizes it offered members for participating in 12

CasCea 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 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, GI CLUBS claimed to the member that the member had requested that the value of the BMW be applied toward an upgrade from a Tier 1 GICLUBS 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 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." 13

CasCea 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 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. 16. All told, investors purchased hundreds of millions of dollars' worth of GIC LUBS 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 of KWOK's 50,000 square foot New Jersey mansion. 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 14

CasCea 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 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 GICLUBS membership payments into a bank account that JE controlled. e. GICLUBS 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 17. 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 l-to-$1 value 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. 18. 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, 15

CasCea 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 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 ....[ I]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 turn 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." 19. The initial coin offering ofHCN 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 offering, the Himalaya Exchange website indicated that HCN purportedly had an approximately $27 billion valuation. 20. 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 16

CasCea 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 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. 21. 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. 22. 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 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). 17

CasCea 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 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. 23. 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 24. 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 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 18

CasCea 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 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." 25. 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. a. As a result of the judicially-authorized seizures, U.S. authorities seized more than approximately $634 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. 19

CasCea 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 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 ofthis Indictment. STATUTORY ALLEGATIONS 26. 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," KIN MING JE, a/k/a "William Je," and Y ANPING WANG, a/k/a "Yvette," 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 240.1 0b- 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). 27. 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," KIN MING JE, a/k/a "William Je," and Y ANPING WANG, a/k/a "Yvette," 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 20

CasCea 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 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, JE, and WANG 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. 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," KIN MING JE, a/k/a "William Je," and YANPING WANG, a/k/a "Yvette," 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, JE, and WANG agreed to fraudulently induce investors to participate in the GTV Private 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. 21

CasCea 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 2 9. 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," KIN MING JE, a/k/a "William Je," and YANPING WANG, a/k/a "Yvette," 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, JE,,and WANG 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. 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," KIN MING JE, a/k/a "William Je," and Y ANPING WANG, a/k/a "Yvette," 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 offenses alleged in Counts Two through Eight of this Indictment in violation of Title 18, United States Code, Section l 956(a)(2)(A)(i). 22

CasCea 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 31. 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," KIN MING JE, a/k/a "William Je," and YA NPING WANG, a/k/a "Yvette," 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 32. 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," KIN MING JE, a/k/a "William Je," and YA NPING WANG, a/k/a "Yvette," 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. 23

.. CasCea 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 b. On or about June 5, 2020, WANG, 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 GICLUBS 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%." 24

CasCea 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 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: 33. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 34. 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, 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," KIN MING JE, a/k/a "William Je," and Y ANPING WANG, a/k/a "Yvette," 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, JE, and WANG 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.) 25

CasCea 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 COUNT THREE (Securities Fraud - GTV Private Placement) The Grand Jury further charges: 35. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 36. 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," KIN MING JE, a/k/a "William Je," and Y ANPING WANG, a/k/a "Yvette," 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.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, JE, and WANG 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 240.1 0b-5; and Title 18, United States Code, Section 2.) 26

CasCea 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 COUNT FOUR (Wire Fraud - Farm Loan Program) The Grand Jury further charges: 3 7. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 38. 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: 39. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 27

CasCea 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 40. 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, 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. 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 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: 41. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 28

CasCea 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 42. 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 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-GICLUBS) The Grand Jury further charges: 43. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 44. From at least in or about June 2020 up to and including at least in or about March 2021, 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, 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 29

CasCea 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 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 promoted and marketed G\CLUBS 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 240.10 b-5; and Title 18, United States Code, Section 2.) COUNT EIGHT (Wire Fraud-The Himalaya Exchange) The Grand Jury further charges: 45. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 46. 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, 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, 30

CasCea 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 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: 4 7. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 48. 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.) 31

CasCea 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 COUNT TEN (International Concealment Money Laundering) The Grand Jury further charges: 49. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 50. 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.) 32

CasCea 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 \ COUNT ELEVEN (Unlawful Monetary Transactions) The Grand Jury further charges: 51. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 52. On or about June 5, 2020, 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," KIN MING JE, a/k/a "William Je," and YA NPING WANG, a/k/a "Yvette," 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(£)(1), in criminally derived property of a value greater than $10,000 that was derived from specified unlawful activity, to wit, KWOK, JE, and WANG 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: 53. The allegations contained in paragraphs 1 through 25 of this Indictment are repeated and realleged as if fully set forth herein. 54. 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 33

CasCea 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 the United States, to impede and interfere with a federal grand jury investigation in the Southern District of New 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 55. 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," KIN MING JE, a/k/a "William Je," and Y ANPING WANG, a/k/a "Yvette," 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; 34

CasCea 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 l 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; 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; 35

CasCea 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 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; 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; 1. $11,538,579.87 in United States currency formerly on deposit in Account Number MBI10103-0000 at Mercantile Bank International held in the name of "G Club International Ltd.," seized by the Government on or about October 16, 2022; m. $10,008,284.04 in United States currency formerly on deposit in Account Number MBil 0133-0000 at Mercantile Bank International held in the name of "Himalaya International Clearing Ltd.," seized by the Government between on or about October 16, 2022 and on or about March 10, 2023; n. $3,090,856.54 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 between on or about October 16, 2022 and on or about March 10, 2023; o. $272,350,313.76 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 between on or about October 16, 2022 and on or about March 10, 2023; p. $310,594.31 in United States currency formerly on deposit in Account Number MBI10139-0000 at Mercantile Bank International held in the name of "Himalaya 36

CasCea 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 International Financial Group Ltd.," seized by the Government between on or about October 16, 2022 and on or about March 10, 2023; q. $1,187,278.87 in United States currency formerly on deposit in Account Number MBI10171-0000 at Mercantile Bank International held in the name of "Hamilton Investment Management Ltd.," seized by the Government between on or about October 16, 2022 and on or about March 10, 2023; r. $43,782.71 in United States currency formerly on deposit in Account Number MBI10172-0000 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 MBI10183-0000 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 37

CasCea 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 ♦ f • 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; z. A 46m 2014 Feadship superyacht "Lady May" (ex Como), bearing IMO Number 112359, MMSI Number 319059500, and Callsign ZGDQ9; aa. A Bosendorfer 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 38

CasCea 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 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." 56. 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," KIN MING JE, a/k/a "William Je," and YA NPING WANG, a/k/a "Yvette," 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 57. 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; 39

CasCea 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 \ 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.) - J:k--;_~ DAMIAN WILLIAMS United States Attorney s\,)''f eQ. ¼~ )~(,... ~' L\.. ..)_ND"! CT°M <c:.N1 1 !50 40