There was a problem locating the requested document.
Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term
Grand Jury Sworn in on May 7, 2019
UNITED STATES OF AMEzuCA
Criminal No.
Count One: 18 U.S.C. s 1es6(h)
(Conspiracy To Launder
Monetary Instruments)
EHH
a/k/a Tian Yinyin,
#*talwa
Li Jiadong
Count Two: 18 U.S.C. $ 1960(a)
(0perating an Unlicensed Money
Transmitting Business)
Forfeiture:
18 U.S.C. $ 982(a)(1);
2l U.S.C. $ 8s3(p)
INDICTMENT
The Grand Jury Charges:
At times material to this Indictment:
INTRODUCTION
l.
The conduct alleged in this Indictment began outside of the jurisdiction ol any
particular State or district, and later occurred within the District of Columbia and elsewhere, and
was therefore within the venue of the United States District Court for the District of Columbia, as
provided by Title I 8, United States Code, Sections 3237(a) and 3238.
2.
In late 2018, a virtual currency exchange ("The Exchange") had been hacked. The
perpetrators of the hack stole nearly $250 million worth ofvirtual currencies.
3.
The hack and subsequent theft and laundering
of funds involved nurnerous
below'
electronic communications made in furtherance of the scheme, including those described
through the United States.
These communications include wire communications that transitedPage 2 4.
Defendants
EEH
a/k/a Tian Yinyin and
4**
a,4
Li Jiadong were Chinese
nationals that accessed the U.S. financial system.
5.
exchanges
Tian Yinyin and Li Jiadong had virtual currency accounts at two virtual currency
("VCE-A" and "VCE-B"). At both VCE-A and VCE-B, Tian Yinyin and Li Jiadong
used the registered usemames "snowsjohn" and "khaleesi," respectively.
6.
Between in or about July 2018 through in or about April 2019, Tian Yinyin and Li
Jiadong engaged in $100,812,842.54 in cryptocurrency transactions, which primarily consisted
of
their exchange of virtual currency traceable to the hack of The Exchange. Tian Yinyin and Li
Jiadong would convert such virtual currency into fiat currency and transfer it to customers, for a
fee.
7.
Tian Yinyin's and Li Jiadong's virtual currency accounts at VCE-A were linked
accounts. The accounts had significant transfers between each other and third-party accounts.
8.
Tian Yinyin linked a bank account at China Guangfa Bank ('CGB") to his VCE-A
account less than a week after the intrusion and theft at The Exchange. This CGB account received
approximately 491 deposits from VCE-A for 233,889,970 CYN (approximatety $34,504,173.43)
and represents proceeds from Tian Yinyin's money laundering activities.
9.
The same CGB bank account was linked to Tian Yinyin's VCE-B account.
10.
Tian Yinyin's VCE-A and VCE-B accounts had no deposits for approximately two
months prior to the hack ofThe Exchange.
I
1.
Tian Yinyin also had an account at
vcE-c, a U.s.-based
exchange, where he would
sell BTC in exchange for prepaid Apple iTunes gift cards, a known method ofmoney laundering.
12.
Tian Yinyin's VCE-C advertisement stated that no ID was necessary for trades.
2Page 3 13.
On multiple occasions, Tian Yinyin, using his account at VCE-C, engaged in
financial transactions to convert virtual cunency to U.S. dollars on behalfofhis customers in the
United States.
14.
Li Jiadong transferred approximately 9.71443 BTC from his VCE-A and VCE-B
accounts to Tian Yinyin's account at VCE-C.
15.
Tian Yinyin exchanged approximately $1,448,694.74 worth of BTC lor iTunes gift
cards via 8,823 transactions from his account at VCE-C.
16.
Li Jiadong's advertisement on another virtual currency exchange ("VCE-D") noted
that he was operating a professional business and gave his hours and payment information.
17
.
Li
Jiadong linked bank accounts at nine Chinese banks-Agricultural Bank
of
China, China Everbright Bank, China CITIC Bank, CGB, China Minsheng Bank, Huaxia Bank,
Industrial Bank, Pingan Bank, and Shanghai Pudong Development Bank-to his VCE-A account.
These bank accounts received approximately 2,000 deposits from VCE-A for 229,282,960.97
CYN (approximately $32,848,567.00) and represent proceeds from his money laundering
activities.
18.
Tian Yinyin's VCE-B account sent approximatety 25 BTC (approximately
$175,000) to Li Jiadong's VCE-A account.
19. Tian Yinyin
and
Li
Jiadong exchanged 2,165.39 BTC (approximately
$15,529,934.00) between each other via VCE-A.
20.
Federal law required money transmitting businesses to be registered with the
Financial Crimes Enforcement Network ("FinCEN"), which is located in the District of Columbia.
The failure to register with FinCEN was a federal felony offense'
-)Page 4 21.
Federal law barred money transmitting businesses from transmitting funds that
were known to be derived from a criminal offense or intended to be used to promote unla*fi.rl
activity.
22.
At all relevant times, Tian Yinyin and Li Jiadong were not registered with FinCEN.
COUNT ONE
(Conspiracy To Launder Monetary Instruments)
23.
The allegations set forth in paragraphs I through 22 ofthis Indictment are re-alleged
and incorporated by reference herein.
24.
From in or about 2018 through in or about April 2019, in the District ofColumbia
and elsewhere, TIAN YINYIN,
LI JIADONG, and co-conspirators known and unknown to the
Grand Jury, conspired with each other and with others known and unknown to the Grand Jury to
violate:
a.
Title 18, United
is,
by
conducting financial transactions which in fact involved the proceeds
of
States Code, Section 1956(a)(1)(AXi), that
specified unlawful activity, to wit, violations
of:
section 1343 (relating to
wire fraud) and section 1960 (relating to illegal money transmitters),
knowing that the property involved
in
such financial transactions
represented the proceeds of some form of unlawful activity, with the intent
to promote the carrying on of said specified unlawful activity;
b.
Title 18, United
is,
by
conducting financial transactions which in fact involved the proceeds
of
States Code, Section 1956(a)(1)(A)(i), that
specified unlawful activity, to wit, violations
of:
section 1343 (relating to
wire fraud) and section 1960 (relating to illegal money transmitters),
knowing that the property involved
4
in
such financial transactionsPage 5 represented the proceeds
of some form of unla*{ul activity, and knowing
that the transactions were designed in whole or in part to conceal or disguise
the nature, the location, the source, the ownership, or the control oi the
proceeds of said specified unlauful activity; and
c.
Title
I 8,
United States Code, Section 1956(a)(2)(A), that is, by transporting,
transmitting, and transferring, or attempting to transport, transmit, and
ransfer monetary instruments and funds from places outside of the United
States to and through a place inside the United States, and from a place in
the United States to or though a place outside the United States, with the
intent to promote the carrying on of specified unlawful activity, to wit,
violations of: section 1343 (relating to wire fraud) and section 1960 (relating
to illegal money transmitters).
25.
It was the goal of the conspiracy for the defendants and other co-conspirators to
unlawfully enrich themselves by: exchanging bitcoin for fiat currency; operating
a
bitcoin money
laundering service that did not collect sufficient data on its customers; and operating an illegal
money transmission service.
(Conspiracy To Launder Monetary Instruments, in violation of
Title 18, United States Code, Section 1956(h))
COUNT TWO
(Operating an Unlicensed Money Transmitting Business)
26.
The allegations set forth in paragraphs
1
through 22 ofthis Indictment are re-alleged
and incorporated by reference herein.
27
.
From in or about 2018 through in or about April 2019, in the District of Columbia
and elsewhere, TIAN YINYIN and
LI JIADONG knowingly
5
conducted, controlled, managed,Page 6 supervised, directed, and owned an unlicensed money transmitting business, as that term is defined
in Title 18, United States Code, Section 1960(bXl), affecting interstate or foreign commerce, and
which:
a.
Failed
to comply with the
money transmitting business registration
requirements under Title 31, United States Code, Section 5330, and the
regulations prescribed thereunder; and
b.
Otherwise involved the transportation and transmission of funds known to
TIAN YINYIN and LI JIADONG to have been derived from a criminal
offense and intended to be used to promote and support unlawful activity;
in violation of Title 1 8, United States Code, Section 1960(a).
(Operating an Unlicensed Money Transmitting Business, in violation of Title 18,
United States Code, Section 1960(a))
FORFEITURE ALLEGATION
l.
Upon conviction of the offenses alleged in Counts One and Two, the defendant
shall forfeit to the United States any property, real or personal, involved in the offense, and any
property traceable thereto, pursuant to Title 18, United States Code, Section 982(a)(1). The United
States
will also
seek a forfeiture money judgment for a sum of money equal to the value of any
property, real or personal, involved in Counts One and Two, and any property traceable thereto.
2.
If any of the property
described above, as a result of any act or omission of the
defendant:
a.
b.
c.
d.
cannot be located upon the exercise of due diligence;
has been transferred or sold to, or deposited with, a third party;
has been placed beyond thejurisdiction of the court;
has been substantially diminished in value; or
has been commingled with other property which cannot be divided without
difficulty,
6Page 7 the defendant shall forfeit to the United States any other property ofthe defendant, up to the value
of the property described above, pursuant to Title 21, United States Code, Section 853(p).
(Criminal Forfeiture, pursuant to Title 18, United States Code, Section 982(a)(1);
and Title 21, United States Code, Section 853(p))
A TRUE BILL:
FOREPERSON.
$. 5L
RNEY OF
UNITED ST
SIN
AND FOR THE DISTRICT OF COLUMBIA
7
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 1 of 7
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term
Grand Jury Sworn in on May 7, 2019
UNITED STATES OF AMEzuCA
Criminal No.
Count One: 18 U.S.C. s 1es6(h)
(Conspiracy To Launder
Monetary Instruments)
EHH
a/k/a Tian Yinyin,
#*talwa
Li Jiadong
Count Two: 18 U.S.C. $ 1960(a)
(0perating an Unlicensed Money
Transmitting Business)
Forfeiture:
18 U.S.C. $ 982(a)(1);
2l U.S.C. $ 8s3(p)
INDICTMENT
The Grand Jury Charges:
At times material to this Indictment:
INTRODUCTION
l.
The conduct alleged in this Indictment began outside of the jurisdiction ol any
particular State or district, and later occurred within the District of Columbia and elsewhere, and
was therefore within the venue of the United States District Court for the District of Columbia, as
provided by Title I 8, United States Code, Sections 3237(a) and 3238.
2.
In late 2018, a virtual currency exchange ("The Exchange") had been hacked. The
perpetrators of the hack stole nearly $250 million worth ofvirtual currencies.
3.
The hack and subsequent theft and laundering
of funds involved nurnerous
below'
electronic communications made in furtherance of the scheme, including those described
through the United States.
These communications include wire communications that transited
PDF Page 3
Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 2 of 7
4.
Defendants
EEH
a/k/a Tian Yinyin and
4**
a,4
PDF Page 4
Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 3 of 7
13.
On multiple occasions, Tian Yinyin, using his account at VCE-C, engaged in
financial transactions to convert virtual cunency to U.S. dollars on behalfofhis customers in the
United States.
14.
Li Jiadong transferred approximately 9.71443 BTC from his VCE-A and VCE-B
accounts to Tian Yinyin's account at VCE-C.
15.
Tian Yinyin exchanged approximately $1,448,694.74 worth of BTC lor iTunes gift
cards via 8,823 transactions from his account at VCE-C.
16.
Li Jiadong's advertisement on another virtual currency exchange ("VCE-D") noted
that he was operating a professional business and gave his hours and payment information.
17
.
Li
Jiadong linked bank accounts at nine Chinese banks-Agricultural Bank
of
China, China Everbright Bank, China CITIC Bank, CGB, China Minsheng Bank, Huaxia Bank,
Industrial Bank, Pingan Bank, and Shanghai Pudong Development Bank-to his VCE-A account.
These bank accounts received approximately 2,000 deposits from VCE-A for 229,282,960.97
CYN (approximately $32,848,567.00) and represent proceeds from his money laundering
activities.
18.
Tian Yinyin's VCE-B account sent approximatety 25 BTC (approximately
$175,000) to Li Jiadong's VCE-A account.
19. Tian Yinyin
and
Li
Jiadong exchanged 2,165.39 BTC (approximately
$15,529,934.00) between each other via VCE-A.
20.
Federal law required money transmitting businesses to be registered with the
Financial Crimes Enforcement Network ("FinCEN"), which is located in the District of Columbia.
The failure to register with FinCEN was a federal felony offense'
-)
PDF Page 5
Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 4 of 7
21.
Federal law barred money transmitting businesses from transmitting funds that
were known to be derived from a criminal offense or intended to be used to promote unla*fi.rl
activity.
22.
At all relevant times, Tian Yinyin and Li Jiadong were not registered with FinCEN.
COUNT ONE
(Conspiracy To Launder Monetary Instruments)
23.
The allegations set forth in paragraphs I through 22 ofthis Indictment are re-alleged
and incorporated by reference herein.
24.
From in or about 2018 through in or about April 2019, in the District ofColumbia
and elsewhere, TIAN YINYIN,
LI JIADONG, and co-conspirators known and unknown to the
Grand Jury, conspired with each other and with others known and unknown to the Grand Jury to
violate:
a.
Title 18, United
is,
by
conducting financial transactions which in fact involved the proceeds
of
States Code, Section 1956(a)(1)(AXi), that
specified unlawful activity, to wit, violations
of:
section 1343 (relating to
wire fraud) and section 1960 (relating to illegal money transmitters),
knowing that the property involved
in
such financial transactions
represented the proceeds of some form of unlawful activity, with the intent
to promote the carrying on of said specified unlawful activity;
b.
Title 18, United
is,
by
conducting financial transactions which in fact involved the proceeds
of
States Code, Section 1956(a)(1)(A)(i), that
specified unlawful activity, to wit, violations
of:
section 1343 (relating to
wire fraud) and section 1960 (relating to illegal money transmitters),
knowing that the property involved
4
in
such financial transactions
PDF Page 6
Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 5 of 7
represented the proceeds
of some form of unla*{ul activity, and knowing
that the transactions were designed in whole or in part to conceal or disguise
the nature, the location, the source, the ownership, or the control oi the
proceeds of said specified unlauful activity; and
c.
Title
I 8,
United States Code, Section 1956(a)(2)(A), that is, by transporting,
transmitting, and transferring, or attempting to transport, transmit, and
ransfer monetary instruments and funds from places outside of the United
States to and through a place inside the United States, and from a place in
the United States to or though a place outside the United States, with the
intent to promote the carrying on of specified unlawful activity, to wit,
violations of: section 1343 (relating to wire fraud) and section 1960 (relating
to illegal money transmitters).
25.
It was the goal of the conspiracy for the defendants and other co-conspirators to
unlawfully enrich themselves by: exchanging bitcoin for fiat currency; operating
a
bitcoin money
laundering service that did not collect sufficient data on its customers; and operating an illegal
money transmission service.
(Conspiracy To Launder Monetary Instruments, in violation of
Title 18, United States Code, Section 1956(h))
COUNT TWO
(Operating an Unlicensed Money Transmitting Business)
26.
The allegations set forth in paragraphs
1
through 22 ofthis Indictment are re-alleged
and incorporated by reference herein.
27
.
From in or about 2018 through in or about April 2019, in the District of Columbia
and elsewhere, TIAN YINYIN and
LI JIADONG knowingly
5
conducted, controlled, managed,
PDF Page 7
Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 6 of 7
supervised, directed, and owned an unlicensed money transmitting business, as that term is defined
in Title 18, United States Code, Section 1960(bXl), affecting interstate or foreign commerce, and
which:
a.
Failed
to comply with the
money transmitting business registration
requirements under Title 31, United States Code, Section 5330, and the
regulations prescribed thereunder; and
b.
Otherwise involved the transportation and transmission of funds known to
TIAN YINYIN and LI JIADONG to have been derived from a criminal
offense and intended to be used to promote and support unlawful activity;
in violation of Title 1 8, United States Code, Section 1960(a).
(Operating an Unlicensed Money Transmitting Business, in violation of Title 18,
United States Code, Section 1960(a))
FORFEITURE ALLEGATION
l.
Upon conviction of the offenses alleged in Counts One and Two, the defendant
shall forfeit to the United States any property, real or personal, involved in the offense, and any
property traceable thereto, pursuant to Title 18, United States Code, Section 982(a)(1). The United
States
will also
seek a forfeiture money judgment for a sum of money equal to the value of any
property, real or personal, involved in Counts One and Two, and any property traceable thereto.
2.
If any of the property
described above, as a result of any act or omission of the
defendant:
a.
b.
c.
d.
cannot be located upon the exercise of due diligence;
has been transferred or sold to, or deposited with, a third party;
has been placed beyond thejurisdiction of the court;
has been substantially diminished in value; or
has been commingled with other property which cannot be divided without
difficulty,
6
PDF Page 8
Case 1:20-cr-00052-TJK Document 1 Filed 02/27/20 Page 7 of 7
the defendant shall forfeit to the United States any other property ofthe defendant, up to the value
of the property described above, pursuant to Title 21, United States Code, Section 853(p).
(Criminal Forfeiture, pursuant to Title 18, United States Code, Section 982(a)(1);
and Title 21, United States Code, Section 853(p))
A TRUE BILL:
FOREPERSON.
$. 5L
RNEY OF
UNITED ST
SIN
AND FOR THE DISTRICT OF COLUMBIA
7
Back to 
