USA v. Shanu Document 2: Complaint

Idaho District Court
Case No. 1:23-cr-00296-BLW
Filed October 26, 2023

CRIMINAL COMPLAINT (Notice sent to USP & USM) as to Olamide Oladosu Shanu (1). (Attachments: # (1) Cover Sheet, # (2) Service Information Sheet) (km)[1:23-mj-00258-REP]

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Page 1 A09l (Rev. 11/11) CriminaJCompiaim:
UNITED STATES DISTRICT COURT
for the
ElJ
District of Idaho
United States of America
V.
OLAMIDE OlADOSU SHANU
)
)
)
)
)
)
)
Defendant(s)
Case No.
23-mj-258-REP
CRIMINAL COMPLAINT
L the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of
District of
February 2023 to May Idaho
Code Sectioll
18 U.S.C. § 1951{a)
18 U.S.C. § 875(d)
18 U.S.C. § 1956{h)
18 u.s.c. § 2261A{2}
18 u.s.c. §
Ada
in the county of
intbe
, the defendant(s) violated:
Offense Description
Extortion
Interstate Communications with Intent to Extort
Conspiracy to Commit Money Laundering
Cyberstalking
Conspiracy (Extortion, Interstate Communications with Intent to Extort,
Cyberstalking)
This criminal complaint is based on these facts:
In or around May 2023, in the District of Idaho, the Defendant, OLAMIDE OLADOSU SHANU did obstruct, delay, and
affect, and attempt to obstruct, delay, and affect, commerce, as that term is defined in 18 U.S.C. § 1951, and the
movement of articles and commodities in commerce by extortion, as that term is defined in 18 U.S.C. § 1951.
if Continued on the attached sheet
Luke Lack,, United States Secret Service SA
Printed name and titk
Sworn to before me and signed in my presence.
Date:
October 26,
City and :state:
Judge's signature
Boise., Idaho
Raymond E. Patricoo. Chief U.S. Magistrate Judge
Printed nrnne and title
Page 2 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF IDAHO
UNITED STATES OF AMERICA,
Case No. 23-MJ-258-REP
Plaintiff,
AFFIDAVIT IN SUPPORT OF
CRIMINAL COMPLAINT AND ARREST
WARRANT
vs.
OLAMIDE OLADOSU SHANU,
Defendant.
I, Luke Lack, Special Agent of the United States Secret Service (“USSS”), being duly
sworn, hereby declare as follows:
1.
I make this affidavit in support of a criminal complaint and arrest warrant for
OLAMIDE OLADOSU SHANU (hereinafter “SHANU”), based upon probable cause for
violations within the District of Idaho of 18 U.S.C. § 1951(a) (Extortion), 18 U.S.C. § 875(d)
(Interstate Communications with Intent to Extort), 18 U.S.C. § 1956(h)(Conspiracy to Commit
Money Laundering), 18 U.S.C. § 2261A(2) (Cyberstalking), and 18 U.S.C. § 371 (Conspiracy to
Commit Extortion, Interstate Communications with Intent to Extort, and Cyberstalking).
2.
I am a Special Agent with the United States Secret Service (“USSS”). I have been
employed as a Special Agent since April 2018. I have completed the Criminal Investigator
Training Program at the Federal Law Enforcement Training Center as well as the Special Agent
Training Course at the United States Secret Service James J. Rowley Training Center. These
programs provided training regarding counterfeit currency, financial crimes, electronic crimes,
fraud, and criminal investigations. I have completed advanced cyber training to include Basic
Computer Evidence Recovery Training (BCERT), Counter-Cyber Investigators Training,
Advanced Computer Evidence Recovery Training (ACERT), Point of Sales (POS) Terminal
1
Page 3 Forensics, AXIOM Advanced Mobile Forensics, and more. I have instructed “Cyber Exploitation
and Investigation” to foreign federal law enforcement partners at the International Law
Enforcement Academy (ILEA) in San Salvador, El Salvador, as well as taught cyber investigative
techniques at the Estonian Federal Law Enforcement Academy in Tallinn, Estonia. I was
previously assigned to the Pittsburgh Field Office, Cyber Fraud Task Force (CFTF) where I
conducted computer forensics and cyber investigations. Since being employed with the USSS, I
have participated in the execution of numerous search warrants, including those for online
accounts, such as email accounts, online storage accounts and other online communication
accounts. I am currently assigned to the U.S. Secret Service Headquarters, Criminal Investigative
Division, Global Investigative Operations Center (GIOC). Prior to joining the United States Secret
Service, I worked as a Police Officer/Investigator for the Illinois Secretary of State Police from
April 2015 to April 2018.
3.
This affidavit is based upon information that I have obtained from my personal
observations, witness and victim interviews, review of documentary evidence, information
provided to me by other members of the investigation, and my training and experience. Because
this affidavit is being submitted only for the limited purpose of establishing probable cause for the
proposed criminal complaint and arrest warrant, it does not include all information known to the
government as a result of the investigation.
FACTS SUPPORTING PROBABLE CAUSE
4.
The USSS, along with Task Force Partner Boise Police Department, is investigating
an international, financially motivated online sextortion scheme and other associated fraud
schemes executed by various individuals located in Nigeria, Africa and elsewhere. Specifically,
I am investigating a sextortion scheme in which SHANU and his conspirators conducted a
2
Page 4 sextortion scheme that targeted males throughout the United States. As described below, SHANU
and his conspirators, using the fake and stolen online accounts, contacted the various male
victims—typically through Instagram or other social media platforms — and persuaded the male
victims to send sexually explicit images and videos of themselves. Once the victims provided the
explicit images, the conspirators threatened to disseminate the images the victims’ friends and
family members unless the victims made payments to the conspirators through various peer-topeer applications. The conspirators used money mules in the U.S. — who typically were also
victims of the scheme —to transmit the payments to the conspirators through the purchase of gift
cards and cryptocurrency. Most of the payments investigators have traced were transferred to a
crypto currency wallet controlled by SHANU.
The Sextortion Scheme
5.
Based on training and experience, I am familiar with the term “sextortion,” which
can take several different forms. The term “sextortion” is generally used in reference to hacking,
coercing, or otherwise obtaining another's private and sensitive material and threatening to
distribute it if they do not provide additional images of sexual nature, sexual favors, or money.
With financially-motivated sextortion, the scheme typically begins when a target contacts a victim
– both minor and adult – over any online platform used to meet and communicate, such as an app
or social media. The victims are usually male. In a scheme that has recently become more
prevalent, the perpetrator poses as an attractive woman and, using deception and manipulation,
convinces the victim to engage in sexually explicit activity over video with “her.” Unbeknownst
to the victim, the activity is recorded or screenshots are taken by the perpetrator. Once the victim
has engaged in the sexually explicit activity, the perpetrator reveals that they have images or
recorded the victim and attempts to extort the victim for money by threatening to post the material
3
Page 5 online and/or release the explicit imagery directly to family, friends, or colleagues of the victim.
Many of the perpetrators are overseas and will often demand money in increasing amounts if any
is sent during the initial request.
6.
Additionally, based on my training and experience investigating sextortion cases,
typically multiple subjects conspire together to complete the extortion. The conspiracy includes
“chatters” who use fake or accounts they have taken over on social media to target and seek out
victims to solicit them to share sexually explicit pictures of themselves. Other individuals involved
in this scheme manage the “chatters,” while other subjects are used to manage the extorted funds
from the victims. United States citizens, both unwitting and complicit and who are often victims
themselves, are used as money mules to transfer funds through layered transactions to the
perpetrators.
7.
In the financially motivated sextortion scenarios under investigation here, the
scheme was executed in a similar manner:
a. The conspirators posed online as young women and, using fake or stolen social
media accounts, they approached men and teenaged boys throughout the United
States.
b.
The conspirators offered to send sexual photographs and videos of themselves
and/or to show their nude bodies on “live chat” sessions or similar online
interaction. In my training and experience, the conspirators likely did not send
sexually explicit images of themselves to the victims but instead used images
available on the open internet and, in this case, images of an adult film actress.
c. The conspirators then fraudulently induced victims to provide sexually explicit
photos or videos of themselves and/or to masturbate on camera during a “live chat”
4
Page 6 session, recorded video, or similar online interaction. Again, the victims believed
they were interacting with a young woman. In reality, the conspirators were not
the women depicted in the photographs, videos, or live chat sessions.
d. During the live chat sessions or similar online interactions, unbeknownst to the
victims, the conspirators made surreptitious video recordings, or took screen shots,
of the victims masturbating.
e. Shortly after the victims provided their sexual images, videos, or engaged in the
live chat sessions, the conspirators threatened to distribute the victims’ sexual
photos and videos unless the victims paid a designated sum using the instructions
provided by the conspirators.
f. As proof that they could follow through with their threats, the conspirators sent the
victims copies of the victims’ sexually explicit photographs and videos.
The
conspirators often made continued demands for additional funds over the course of
months, and in some cases years. In many cases, the conspirators additionally
include screen shots of draft messages to the victim’s family and/or friends on
social media, informing the victim that the target has a message ready to send,
together with the images, to the victim’s contacts on social media. The conspirators
used, and continue to use, a variety of platforms for their online communications
with victims, including Snapchat, TikTok, Instagram, as well as email, text
message, and voice phone call services.
g. The conspirators also used, and continue to use, a variety of methods to transfer the
sextortion payments, including peer-to-peer transfer systems like Cash App,
PayPal, Venmo, and crypto currency services. The conspirators also directed the
5
Page 7 victims to purchase stored value cards like iTunes gift cards and transfer the
necessary card information to members of the conspiracy.
h. In addition to receiving payments directly, the conspirators directed the victims to
transfer the funds to specified accounts and individuals believed to belong to
suspected money mules. They then used a network of suspected money mules to
launder the sextortion payments. As directed, these money mules, many of whom
live in the U.S., received funds from the victims and then transferred the funds to
other suspected members of the conspiracy.
8.
Several of the suspected money mules in this investigation have been contacted and
interviewed. As described more fully below, these individuals stated that they were victimized by
the same sextortion scheme and then coerced into becoming a money mule for the conspirators.
Victim 9.
This scheme first came to the attention of law enforcement in May 2023, when
Boise Police Department (“BPD”) received a report about a sextortion victim— an adult male
student from a nearby university (“Victim 1” or “V1”).1 V1’s mother contacted BPD about her
son’s sextortion and provided a written statement. BPD then contacted V1 directly who
corroborated his mother’s statement and provided his own written statement via email.
10.
Based on V1’s statements, conversations with V1’s mother, conversations with
other law enforcement officers about V1, my review of records provided by V1, and records
obtained from search warrants executed in this investigation, I have learned the following in
substance and part:

V1’s identity is known to USSS but for purposes of privacy, has been withheld in this Affidavit.
6
Page 8 a. In May 2023, V1 received a friend request on Snapchat from an unknown subject
who identified herself as “Chloe Walterz” (“Chloe”), using the Snapchat moniker
“chloe.walterz.” V1 stated that in images exchanged on Snapchat, Chloe appeared
to be a white female approximately 20-30 years of age. During the conversations
with Chloe, V1 was solicited to send sexual pictures of himself after receiving
sexual images of the female he believed was Chloe. Once V1 sent his explicit
images, Chloe informed V1 that she had saved his sexually explicit images and she
began to extort V1 for payments.
b. V1 stated that almost immediately “Chloe” began a voice call through the Snapchat
application in which V1 heard a male voice instruct him to pay $300 via Venmo to
the Venmo account “@Tybo0302.” V1 noted that the voice appeared to have a
strong accent of unknown origin. V1 asked his mother for the money and made the
$300 payment. V1 was again solicited and paid another $200 payment to the same
Venmo account. V1 was solicited for a third time and paid an additional $500 to
the same Venmo account, for a total of $1,000. When V1 was solicited for a fourth
payment, he declined. Chloe then requested V1 purchase a $20 iTunes gift card,
which he declined and blocked Chloe on Snapchat.
c. V1 stated that the same day he blocked Chloe on Snapchat, he was contacted by
another Snapchat account, camille_smith96, hereinafter “Camille.” Camille sent
V1 an image that appeared to show Camille sending V1’s sexually explicit picture
—one that he had originally sent to Chloe — to one of V1’s friends on Snapchat.
This exchange indicates that the Camille Snapchat account was likely controlled by
7
Page 9 the same conspirators who control the Chloe snapchat account. V1 blocked Camille
on Snapchat after receiving that image.
The “Chloe” and “Camille” Snapchat Accounts
11.
Investigators obtained a search warrant for both the Chloe and Camille Snapchat
accounts. The two accounts had matching internet protocol addresses (“IP address(es)”), further
indicating that the same conspirators controlled both the Camille and Chloe Snapchat accounts.
For example, on May 31, 2023 at 23:25:27 UTC the conspirators logged into the Chloe Snapchat
account with the IP 105.112.18.206 which resolves to Lagos, Nigeria. On the same date,
approximately 18 minutes later, at 23:53:19 UTC, the conspirators logged into the Camille
Snapchat account from the same IP, again demonstrating that the same conspirators control both
accounts. There are several instances of IP overlap between the accounts.
12.
Further review of the Snapchat search warrant return for the Chloe and Camille
Snapchat accounts revealed multiple other victims. Additionally, investigators found evidence in
the search warrant return in which the conspirators perpetrated account takeovers from the original
Chloe and Camille Snapchat account owners. The account “chloe.walterz” originally had been
named “haileysalin21.” Based on a review of the logs of the Snapchat account, it appeared that the
account had been legitimately owned and used by a 16-year-old female. The account was
fraudulently taken over in February 2023, at which point the phone number was changed to a
Nigerian based telephone number and the display name was changed to “Chloe Walterz.”
Investigators have been unable to contact the original owner, likely because she is underage and
not available in many law enforcement databases.
8
Page 10 13.
The account “camille_smith96” originally had been named “talston963.” The
original email associated to the account had been “REDACTED@gmail.com2” but was changed
to snaphelp772@gmail.com after the conspirators took over the account. Investigators were able
to speak with the original owner of the account, a teenage female, hereinafter “Takeover V1.”
Takeover V1 was a minor at the time her Snapchat account was fraudulently taken over. Takeover
V1 confirmed that the “talston963” Snapchat account was hers and that she had lost access to her
Snapchat account after it had been “hacked.” During the interview, Takeover V1 provided the
following information:
a. Takeover V1 recognized the original email as her mother’s and the original
username as hers, but she did not recognize the new username and email associated
with the account.
b. It had been several months since her Snapchat had been taken over and she did not
remember the exact details.
c. Takeover V1 remembered someone offering to pay her money on CashApp if she
would agree to change the email associated with her account, but she did not
remember her reply.
14.
Investigators were able to locate the chats in which Snapchat user “akapalottt”
initiated the takeover fraud by promising Takeover V1 $3,000 to be paid to her via CashApp to
change her recovery email address to the email snaphelp772@gmail.com. The parsed chat is
displayed below.

This is email is redacted to protect the individual’s privacy.
9
Page 11 15.
Reviewing the logs provided by Snapchat in the search warrant return, investigators
determined the recovery email address was changed to snaphelp772@gmail.com on April 10,
2023. On that same date, the password was then reset by user, indicating that the conspirators
controlling the snaphelp772@gmail.com utilized the email’s new connection as the recovery email
address to the fraudulently taken over Snapchat by resetting the password. Continuing on that date,
the IP addresses used to log into the account changed from IP addresses resolving to Takeover
V1’s place of residence in the United States to IP addresses resolving to Nigeria. Not long after
the conspirators gained control of the account, on April 21, 2023, the account name changed from
“talston963” to “Camille_smith96” with the display name “Camille_smith.” Based on my training
and experience, it appears that conspirators located in Nigeria, controlling the Snapchat account
“akapalottt” and the Google account “snaphelp772@gmail.com,” conducted a fraudulent account
takeover of the “talston963” Snapchat account to perpetuate the sextortion scheme.
16.
The Camille and Chloe Snapchat accounts contained other similar email addresses
that that were used in chats between the conspirators and other individuals who appear to be other
10
Page 12 victims. Based on the contents of these chats, the users of the email addresses were attempting to
takeover other Snapchat accounts. Based on my training and experience, these are other email
accounts the conspirators set up for the purpose of appearing to be associated with the official
Snapchat platform and were likely being utilized in the same way that “snaphelp772@gmail.com”
was used in the original takeover of Takeover V1’s account.
Victim 17.
During the investigation of the sextortion scheme, V1’s mother was interviewed.
She stated that she had attempted to contact the individual to whom V1 sent his extortion payments
in an effort to recover the extortion payments V1 had made. The Venmo profile @Tybo0302 —
the account to which V1 sent his payments — was public, so V1’s mother was able to determine
the name and phone number of the recipient of the funds sent by V1. She provided this individual’s
(“Victim 2” or “V2”) information to investigators.
18.
Investigators contacted V2 and V2’s father, both of whom lived in Traverse City,
Michigan. Investigators interviewed V2 in-person. Based on V2’s interview, conversations with
V2’s father, conversations with other law enforcement officers about V2, my review of records
provided by V2, and records obtained from search warrants executed in this investigation, I have
learned the following in substance and part:
a. V2 confirmed that his Venmo account, @Tybo0302, received payments from Vand other victims of the “sextortion scheme.”
b. V2 had been victimized by the same sextortion scheme and had been coerced to
receive payments from other victims. Pursuant to instructions provided to him by
the conspirators, once he received the payments through his Venmo account, he
11
Page 13 would forward them to conspirators —and in particular, a crypto currency wallet
controlled by SHANU — at their instruction.
c. V2 stated that he made one transaction to a “Jasmine Simpson” via Venmo
@jazzy30 but, after that payment, he was instructed to send all other payments via
cryptocurrency.
d. V2 stated that he was given two addresses to send cryptocurrency payments to.
During the first transaction he sent a cryptocurrency payment through a crypto
ATM; however, after difficulties with that transaction, he sent all subsequent
transactions via cryptocurrency through Cash App.
e. On April 3, 2023, V2 received an unsolicited friend request on Instagram from a
female identified as Camille or Chloe. V2 could not recall at the time of interview
which name he spoke with first, as over the course of the extortion the names
changed. The female contacted him with the Instagram username “camillesmith.”The user of the camillesmith Instagram account asked V2 to move communications
to a Snapchat account named Chloe, but V2 could not recall the exact username.
f. V2 and “Chloe” —whom V2 thought was a young, white female— exchanged
sexually explicit images on Snapchat.
g. Soon after exchanging images, V2 began to receive Apple iMessages from
chloewalterz@icloud.com. V2 stated he was confused at the time because the
individual he believed he was communicating with was using both the names
“Camille” and “Chloe.” When V2 questioned the use of both names, the unknown
The username “camillesmith” is similar to the Snapchat username “camille_smith96” used to
defraud V1.

12
Page 14 conspirators threatened to expose V2’s sexually explicit images as demonstrated in
a screenshot below.
h. To prevent the conspirators from sending his sexually explicit images to his friends
and family on social media, V2 agreed to pay $300 every Friday until he had paid
a total $10,000 of his own money. This amount was agreed upon after V2 paid an
initial $1500.
19.
Based on my training and experience, it is common that perpetrators of sextortion
schemes often have their victims also receive and launder funds from other victims, in an attempt
to obfuscate the money trail back to the perpetrators.
20.
V2 voluntarily provided his cellular telephone to investigators who made a
forensic copy of the contents. The text messages, and other content of the cell phone’s forensic
copy, corroborated V2’s account of victimization as shown in the screen shot below:
13
Page 15 21.
V2’s phone extraction also contained a screenshot apparently taken by V2 of a
message chloewalterz@icloud.com sent to him on or about April 7, 2023. In the message,
chloewalterz@icloud.com threatened to release V2’s sexually explicit images and had attached
V2’s sexually explicit images, as well as a screen capture of what appeared to be a database
detailing V2’s name, address, and the original extortion message. The conspirators also attached
a draft message to V2’s friends and family to be disseminated through social media. Below is a
copy of the screen shot, edited to cover the victim’s sexually explicit images, name, and other PII
for purposes of this affidavit. Those details were present in the original image the conspirators sent
to V2 extorting him.
14
Page 16 22.
In my training and experience, the scenario described above is a typical method
sextortion suspects use pressure their victims to make payments. This method includes sending
communications to the victim that includes the following: 1) the sexually explicit images the
victim previously sent to the conspirators; 2) the victim’s real name and location; and, 3) a draft
message that the conspirator has prepared to send to the victim’s family together with the victim’s
sexually explicit images.
23.
demands
After receiving the threats from the conspirators, V2 complied with the conspirators
and
sent
payment
to
a
crypto
currency
wallet
address,
Page 17 1HYabmNtJa8dBdrtfdHHGMLbCxtZhHS4TU (“1HYab”). V2 stated he made payments to that
address via CashApp and a Bitcoin ATM, and that at the time he was receiving V1’s payments,
and sending them on to the conspirators, the funds were sent to the 1HYab address. The
conspirators
also
provided
V
with
a
second
address,
bc1qhdsw4nvhmyvzpz9ys3pwnm5l5m2esn28gke6p2 (“bc1qh”), and instructed him to deposit
funds into that account as well.
The Binance Account and Associated KYC
24.
Investigators determined the bclqh address to be an un-hosted wallet that was used
to make transfers to the 1HYab address. In turn, the 1HYab address was determined to be an
address hosted by Binance. I am aware that Binance is a popular cryptocurrency exchange and will
provide “Know your Customer” information (“KYC”) upon legal request. Investigators submitted
the legal request relating to the 1HYab address and in response, Binance provided KYC including
the customer’s address and account transaction information.
25.
According to the information Binance provided, the 1HYab address is associated
with a wallet registered by Olamide Oladosu Shanu, a Nigerian National (“SHANU”). KYC
information
included
a
phone
number
of
+234-0703-080-
and
an
email
of
olamideshanu011@gmail.com. A Nigerian Passport and photograph of SHANU were additionally
included in the KYC information, along with an address of Lagos, Nigeria. All IP addresses
utilized to access the Binance account also resolved to Lagos, Nigeria, which is consistent with
the IP addresses from the Snapchat account takeovers utilized in the sextortion scheme.
Additionally, several devices were listed that had been utilized to access the Binance account, with
one device named “Olamide’s iPhone”.
16
Page 18 26.
Below is a photograph of a Nigerian passport that Binance received from the
individual that opened the account at Binance as part of Binance’s KYC.
27.
Below is a photograph that the individual who opened the 1HYab address provided
to Binance as part of Binance’s KYC. This photograph appears to be the same individual depicted
in SHANU’s passport photograph.
17
Page 19 28.
The transaction information Binance provided indicated that the1HYab address had
a current balance of 0 BTC; however, the address had received 84.66478598 BTC
($2,560,049.730) and transferred $2,553,918.99 in BTC over a period of approximately three (3)
years. Based on my training an experience this large amount of money and transactions that have
occurred indicates that the 1Hyab address is being used as a funnel account to receive funds from
multiple sources, many of which have been identified from victims of various fraud schemes,
including sextortion and romance scams. Based on analysis conducted by investigators, SHANU
typically sold the funds deposited into the 1Hyab address to other Binance users in exchange for
Nigerian currency which was then deposited into Nigerian banks held in his name.
29.
As a specific example of the flow of funds to SHANU, using analysis of records,
screen shots, victim interviews and more, investigators determined that V1 transferred $1,through three separate payments to V2 via Venmo on or about May 2, 2023. V2 was instructed to
transfer V1’s funds to the 1Hyab address. Within days of receiving V1’s payments, V2 transferred
funds to SHANU’s address at 1Hyab.
18
Page 20 The olamideshanu011@gmail.com Account
30.
Based on the KYC information provided by Binance about the owner of the account
connected to the receipt of sextortion payments, investigators obtained a search warrant for the
Google account “olamideshanu011@gmail.com.” In reviewing the search warrant return for the
olamideshanu011@gmail.com Google account (“SHANU Google Account”), investigators
located files indicating SHANU controls the Google account. For example, the account contained
various images of SHANU that matched the image provided to Binance for KYC documents as
well as other documents such as exam results from “The West African Examinations Council”
with SHANU’s name listed, business records, certificates/diplomas, and more.
31.
Additionally, the SHANU Google account contained multiple images, including
photographs and screenshots, that indicate SHANU’s involvement in the sextortion scheme and
other related schemes. One such screenshot, displayed below, appears to be a photo taken of a cell
phone showing a payment made to SHANU’s 1HYab address. Additionally, the screenshot seems
to show the potential victim attempting to negotiate with the user of the account “chloewalterz88,”
which is similar to the Snapchat and iCloud account that included the name “Chloe Walterz.” This
screen shot has been edited to remove the victim’s name.
19
Page 21 Victim 32.
Investigators
discovered
multiple
other
sextortion
victims
within
the
olamideshanu011@gmail.com Google account. For example, the account contained screenshots
from Victim 3’s (“V3”) 4 Snapchat account which included chats in which V3 was negotiating the
sextortion payments. Upon learning his identity, investigators spoke with V3 who indicated he was

V3’s identity is known to USSS but for purposes of privacy, has been withheld in this Affidavit.
20
Page 22 sextorted as part of this scheme. The images below discovered in SHANU’s Google account have
been edited to protect the identity and location of V3.
Victim 33.
Investigators also identified Victim 4 (“V4”) while reviewing SHANU’s Google
account.5 Investigators contacted V4 who provided information and records related to the scheme.
Based on V4’s interview, conversations with other law enforcement officers about V4, my review

V4’s identity is known to USSS but for purposes of privacy, has been withheld in this Affidavit.
21
Page 23 of records provided by V4, and records obtained from other search warrants executed in this
investigation, I have learned the following in substance and part:
a. V4 was initially contacted by the conspirators through his Snapchat account on
approximately May 24, 2023.
b. V4 was a 17-year-old minor as the time of his sextortion but is now a young adult
attending college.
c.
Using Snapchat, the conspirators instructed V4 to answer a voice call through the
Snapchat application, or the conspirators would send V4’s compromising images
out. V4 was given instructions for payment via the call.
d. V4 was instructed to make a $210 payment via Cash App to $ajsmith0110, which
V4 attempted and did not go through. Evidence of this attempted payment was
discovered in SHANU’s Google return, as displayed below. V4 was further
instructed to make additional payments elsewhere.
34.
Evidence of V4’s payment, contained in SHANU’s Google account, is shown
below:
22
Page 24 35.
Using V4’s Snapchat username that he provided to investigators,
investigators were able to find communications between V4 and the same “Camille”
Snapchat account that the conspirators used to extort V1—further linking SHANU to the
originally known Snapchat accounts used for the sextortion of V1. Also, as a tie to other
sextortion victims, while reviewing the chloe.walterz@icloud.com account, V4’s phone
number was discovered as a number that the chloe.walterz@icloud.com had placed two
calls to on May 25, 2023.
23
Page 25 36. Based on the foregoing information, I respectfully submit that there is probable
cause to believe that on or about the following dates outlined in the Counts below, in the District
of Idaho and elsewhere, SHANU committed violations of 18 U.S.C. § 1951(a) (Extortion), U.S.C. § 875(d) (Interstate Communications with Intent to Extort), 18 U.S.C. § 1956(h)
(Conspiracy to Commit Money Laundering) 18 U.S.C. § 2261A(2) (Cyberstalking), and 18 U.S.C.
§ 371 (Conspiracy to Commit Extortion, Interstate Communications with Intent to Extort, and
LZ
Jou Lack
Special Agent
United States Secret Service
Cyberstalking).
Subscribed and sworn to before me on this 26th day of October, 2023.
O Capua Ob cee
Honorable Raymond E. Patricco
Chief United States Magistrate Judge

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