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Page 1 Case 1:23-cr-00296-BLW Document4 Filed 11/14/23 Page 1 of 21
U.S. COURTS
JOSHUA D. HURWIT, IDAHO STATE BAR NO, 9527 NOV +4 2003
UNITED STATES ATTORNEY
BRITTNEY CAMPBELL, NORTH CAROLINA STATE BAR NO. 31433 — Reva Filad THC ecm"
ASSISTANT UNITED STATES ATTORNEY STEPHEN W, KENYON
SEAN M, MAZOROL, OREGON STATE BAR NO. 116398 CLERK, BISTRIGT GF IDAHO *
ASSISTANT UNITED STATES ATTORNEY
DISTRICT OF IDAHO
1290 W. MYRTLE ST, SUITE 500
BOISE, ID 83702-7788 ,
TELEPHONE: (208) 334-1211
FACSIMILE: (208) 334-1413
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF IDAHO
UNITED STATES OF AMERICA, Case No. Ca 3 3 _ q 3 9 é . G a
Plaintiff,
INDICTMENT
VS.
18 ULS.C, § 2
OLAMIDE OLADOSU SHANU, 18 US.C, § 371
18 U.S.C. § 875¢d)
Defendant. 18 ULS.C. § 981 (a) (A)
18 U.S.C. § 981 AKC)
18 U.S.C. § 982(a)
18 U.S.C. § 1028A
18 US.C. § 1343
18 U.S.C. § 1349
18 U.S.C. § 1951 (a)
18 U.S.C. § 1956(h)
18 U.S.C. § 2261A(2)
28 U.S.C. § 2461(c)
The Grand Jury charges:
At all times relevant to this Indictment:
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GENERAL ALLEGTIONS
1, OLAMIDE OLADOSU SHANU was a resident and national of Nigeria.
2. Unindicted coconspirator 1 (CC-1) was a resident and national of Nigeria.
3, Unindicted coconspirator 2 (CC-2) was a resident and national of Nigeria.
4, Unindicted coconspirator 3 (CC-3) was a resident of Michigan.
5, Unindicted coconspirator 4 (CC-4) was a resident of Oregon.
6. Victim-1 was a resident of Idaho and a student at a university in Idaho.
7, A “money mule,” as used in this Indictment, was a person who transfers illegally
acquired money on behalf of, and at the direction of, other individuals.
8. An “account takeover” as used in this Indictment, refers to theft and obtaining
control of another person’s legitimate pre-existing online account through fraudulent, deceptive,
or otherwise illegal means.
Overview of the Extortion and Fraud Schemes
9. From in or around November 2020 through in or around May 2023, the
defendant, SHANU and other coconspirators, known and unknown to the Grand Jury, were
engaged in a conspiracy to commit sextortion, romance scams, and other types of cyber-enabled
fraud schemes targeting individuals across the United States.
10. The schemes were typically organized, with coconspirators generally having
specific roles in the conspiracy. The coconspirators included “chatters,” such as CC-1 and CC-2,
who used fake social media accounts —or stolen social media accounts acquired via what is
known as “account takeover” —to target and seek out victims. In addition to establishing the
online “relationships” with the victims, the “chatters” provided the victims with the payment
demands and instructions about how and where to make the payments, Other coconspirators
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involved in the schemes managed the “chatters,” while other coconspirators, including SHANU,
primarily, but not exclusively, managed the funds obtained from the victims. United States
citizens, both unwitting and complicit and who were often victims themselves, including CC-3
and CC-4, were used as money mules to transfer funds through layered transactions to the
coconspirators,
11. The “sextortion” schemes were typically executed in a similar manner. The
coconspirators, posing as females, contacted victims, typically males, through social media using
fake accounts and taken-over accounts and persuaded the victims to send sexual images and/or
videos of themselves. Once the victims provided the explicit images and/or videos, the
coconspirators threatened to disseminate the images to the victims’ friends and family members
and/or to post them widely online unless the victim made payments to the coconspirators through
vatious peer-to-peer payment applications (““P2P Apps”), cryptocurrency transfers, and/or
through the purchase of gift cards. The coconspirators falsely assured the victims that if they
paid the demanded funds, the coconspirators would delete and/or refrain from distributing the
victims’ images.
12. The “romance scams” also followed a similar pattern. The coconspirators, using
fake identities on social media platforms, made contact with the victims and established
deceptive emotional relationships. The coconspirators gained the victims’ trust, persuaded the
victims first that they had a romantic future together and later that the coconspirators had urgent
needs for money, and then convinced the victims to send them money through P2P Apps, gift
cards, and/or eryptocurrency.
13. | SHANU and his coconspirators frequently used victims-turned-money mules to
receive and transmit the payments from the victims. Victims were instructed to make payments
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to the money mules using various P2P Apps stich as Venmo, Zelle, and CashApp. Frequently, as
directed by the coconspirators, the money mules then used the funds they received from the
victims to purchase and send cryptocurrency to wallet addresses provided by the coconspirators.
Other times, victims and money mules were instructed to purchase gift cards and transfer them to
the coconspirators.
14, SHANU and his coconspirators targeted numerous victims across the United
States, the exact number unknown to the Grand Jury, and from 2020 through 2023, Defendant
obtained at least $2 million in payments to a cryptocurrency address controlled by Defendant,
which was transferred offshore, including to multiple bank accounts in Nigeria.
Vietim-1
15. Coconspirators first made contact with Victim 1 (V-1), a student attending college
in Idaho, in May 2023, when an unknown “woman,” a coconspirator, began following V-1’s
account on the social media platform Instagram. Shortly after, V-1 and the unknown “woman”
began messaging on the social media platform Snapchat using the platform’s text chat function.
The unknown coconspirator used the Snapchat account “[female first name and last name with
initials C,W.]” (“Snapchat User 1”) to communicate with V-1 and appeared to be a white female
approximately 20-30 years of age. Snapchat User 1 sent V-1 what purported to be an explicit
photo of “herself” and persuaded V-1 to send an explicit photo of himself. When V-1 sent his
explicit photo, he was notified via the app that Snapchat User 1 had taken a screen capture of his
image that otherwise would have disappeared after a few moments.
16, Shortly after V-f sent his explicit image, on or about May 2, 2023, Snapchat User
sent V-1 a message using the Snapchat chat function and informed him, in substance, that if V-
did not follow Snapchat User i’s instructions, V-1’s explicit photo would be sent to everyone
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V-1 knew, all of his friends, and his life would be ruined. Along with this threat, Snapchat User
included a screenshot of what appeared to be a draft message in which an unknown person was
poised to send V-1’s explicit photo to his friends on Instagram.
17. Snapchat User 1 demanded a payment of $300 and provided V-1 with instructions
to send the payment to a Venmo account that belonged to CC-3. Snapchat User | also told V-1
that if he made the payment, then that would be the end of the extortion. After V-1 made the
initial $300 payment, Snapchat User 1 immediately made multiple additional demands for
payment. V-1 made an additional two payments which, along with his initial payment, totaled
$1,000. After making his third payment, the coconspirators demanded additional money. V-1
informed them that he would not make any additional payments.
18. After V-1 refused to make an additional payment, an unknown coconspirator
contacted V-1 using the Snapchat voice call function. The caller, who was male and spoke with
a strong accent, threatened V-1, and informed him that if he did not find a way to send additional
money then the caller would send V-1’s explicit photo to all of V-1’s friends. Despite the threat,
V-1 did not make additional payments, reported the fraud to Venmo, and blocked Snapchat User
1’s account.
19. V-1 was then contacted on Snapehat by a Snapchat account called [“C.S.96"]
(“Snapchat User 2”). Believing Snapchat User 2 to be the same individual as Snapchat User 1,
V-1 accepted Snapchat User 2’s friend request. Snapchat User 2 called V-1 using the Snapchat
voice call function. V-1 believed the voice was the same caller that had previously contacted
him and demanded payment. Snapchat User 2 questioned V-1 about reporting the fraud to
Venmo and again threatened to send V-I’s explicit photo to his friends unless he made additional
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payments, V-I refused to make any additional payments and, after blocking Snapehat User 2,
had no further contact with the coconspirators.
Coconspirators 1 through 4
20. Snapchat User 1 and Snapchat User 2 were both Snapchat accounts the
coconspirators fraudulently obtained from legitimate owners through account takeovers.
a, The “C.W.” account, used in the scheme by Snapchat User 1, was
originally owned by a female minor. 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 “C.W.”
b. The “C.S. 96” account, used by Snapchat User 2, was also owned by a
female minor. The account was taken over in or around April 2023. In executing the account
takeover, the coconspirators persuaded the original owner to change the recovery email address
to an address the coconspirators controlled. The coconspirators immediately changed the
password and took contro] of the account.
21. CC-3, the owner of the Venmo account that V-1 was instructed to pay, was also a
victim of the same sextortion scheme. Like V-1, CC-3 had been contacted by a coconspirator
posing as a young woman using names similar to the Snapchat User 1 and User 2 accounts. The
coconspirator persuaded CC-3 to send explicit images of himself. The coconspirator then
threatened to send CC-3’s explicit image to friends and families unless he paid $10,000. CC-3
agreed to pay $300 every week until he had paid the full amount. During this tune period, CC-3
was also coerced to serve as a money mule by receiving payments from other victims through his
Venmo account, The coconspirators directed CC-3 to purchase cryptocumency using the funds
he received from the other victims, including the funds he received from V-1, and then send the
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cryptocurrency to two wallet addresses the coconspirators controlled, including an address
owned by SHANU.
22, CC-4 was initially a victim of the romance fraud scheme. She believed she was in
a romantic relationship with an individual calling himself “Scott Bowman” (“Bowman”). In
addition to sending thousands of dollars of her own money to Bowman or to others at Bowman’s
behest, the coconspirators used CC-4 as a money mule, transmitting thousands of dollars from
victims to the coconspirators. Since 2020, CC-4 has sent a substantial amount of money to
SHANU’s 1HYab cryptocurrency wallet address, among others, She was also instructed to
purchase gift cards and conduct other financial transactions on behalf of the conspiracy.
COUNT ONE
Conspiracy to Commit Wire Fraud
18 U.S.C. §1349
23, The allegations set forth in paragraphs 1 through 22 are hereby realleged as if set
forth herein.
24. From in or around November 2020 and continuing to in or around May 2023, the
exact dates being unknown to the Grand Jury, in the District of Idaho and elsewhere, the
defendant, OLAMIDE OLADOSU SHANU, together with others known and unknown to the
Grand Jury, did knowingly and willfully combine, conspire, confederate, agree, and have a tacit
understanding with each other to devise and intend to devise schemes and artifices to defraud, as
to material matters, including sextortion, romance scams, and other cyber-enabled fraud
schemes, and fo obtain money and property, by means of materially false and fraudulent
pretenses, representations, and promises, and, in so doing, caused interstate and foreign wire
communications to be made, in furtherance of the schemes and artifices to defraud, in violation
of 18 U.S.C. § 1343,
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Object of the Conspiracy
25. It was a purpose of the conspiracy for the defendant, SHANU, and his
coconspirators to unlawfully enrich themselves by participating in a variety of cyber-enabled
fraud schemes, including sextortion and romance scams, that targeted individuals throughout the
United States.
Manner and Means
26. To further the objects of the conspiracy, Defendant and his coconspirators, known
and unknown, used the following manner and means, among others:
27. Defendant and his coconspirators engaged in account takeovers and creation of
fake social media accounts.
28. Defendant and his coconspirators utilized interstate and foreign wires to (1)
contact victims through various social media platforms including Snapshat and Instagram, (2)
communicate with victims using WhatsApp; (3) obtain payments from victims using various P2P
payment apps such as Venmo and CashApp; and (4) cause victims and money mules to purchase
and transfer cryptocurrency to various addresses in hosted and un-hosted cryptocurrency wallets.
29, Defendant and his coconspirators contacted victims of the sextortion schemes
using the fake and stolen social media accounts posing primarily as young females.
30, Defendant and his coconspirators convinced victims to send them explicit images
and videos.
31. Defendant and his coconspirators threatened to send the explicit images and
videos to friends and family of the victims unless the victims made payment to Defendant and
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his coconspirators. The coconspirators used and shared a common written “script” of how to
make threats and extort money from victims, including, but not limited, to the following:
32,
Hey I have ur nudes and everything needed to ruin your life, 1 have
screenshot all ur followers and tags and those that comment on ur
post. I can send this nudes to everyone in your city till it go virals
or send this all females on your list and your family if u don’t
cooperate..,.all u have to do is to cooperate with me and i will not
expose u, if u block me i will ruin your life
FOR THE FACEBOOK POSTING
Hello famz this is [name of victim] naked pictures and dick he’s
[(victim user name)] on Instagram...he tried to hurt me so ’'m
spreading his nudes m to make him feel ashamed all i want you
guys to share this pictures all over the world till it goes viral and get
to ail his friends and family that’s all.
Ul
I’ve been doing this for years now
Over 10 years,,J’ve done this to lot of cops and top people in the
state and as soon as they do what I want I let them go cuz I always
do as I’ve promised
And when they try to prove stubborn with me... expose them like I
do promise and when that happens it ruin their career, their
relationship, their family get shattered and they lose other
opportunities too
Defendant and his coconspirators made materially false and fraudulent pretenses,
representations, and promises to the sextortion victims to obtain money and property from the
victim, including falsely telling the victims that if they paid the specific amount initially
demanded, then the sextortion would end.
33.
Defendant and his coconspirators adopted fake online identities and
communicated with victims of the romance scams to gain the affection and trust of individuals.
34,
Defendant and his coconspirators initiated contact with the victims of the romance
scams by sending victims emails, text messages, and messages through online dating and social
*
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media websites that deceived the victims into believing they were in relationships with a person
who was, in fact, a fake identity assumed by the coconspirators.
35, Defendant and his coconspirators convinced the romance scam victims, under
false representations, promises, and/or pretenses, to transfer money and payments to the
coconspirators.
36. Defendant and his coconspirators made materially false and fraudulent pretenses,
representations, and promises, of a romantic and close relationship to obtain money and property
from the romance scam victims,
37, Defendant and his coconspirators caused the victims of the sextortion and
romance scams to transmit money and property by means of wire communication in interstate
and foreign commerce to Defendant and his coconspirators.
38. Defendant and his coconspirators caused the victims of the sextortion and
romance scams to send payments to cryptocurrency addresses controlled by Defendant and his
coconspirators.
39, Defendant and his coconspirators coerced and manipulated victims of sextortion
and romance scams to act as money mules for the sextortion, romance scams, and other cyber-
enabled fraud.
40. Defendant and his coconspirators used the money mules to receive the payments
from the fraud victims, typically via P2P payment apps, and then launder the fraud proceeds by
converting those proceeds to cryptocurrency and sending to addresses provided and controlled by
Defendant and his coconspirators, known and unknown.
41. Defendant and his conspirators also instructed the money mules to purchase gift
cards and provide the cards and/or card information to the coconspirators.
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42. Defendant and his coconspirators frequently sold the cryptocurrency through one
ot more cryptocurrency exchanges and deposited the funds into multiple bank accounts primarily
located in Nigeria.
Allin violation of 18 U.S.C, § 1349.
COUNT TWO
Aggravated Identity Theft
18 U.S.C. § 1028A
43. The allegations set forth in paragraphs | through 22 and 28 through 41 are hereby
realleged as if set forth herein.
44, Beginning in or around February 2023 through in or around April 2023, in the
District of Idaho and elsewhere, the defendant, OLAMIDE OLADOSU SHANU, and his
coconspirators, known and unknown to the Grand Jury, without lawful authority, did knowingly
possess, transfer, and use, a means of identification of another person, during and in relation to a
felony violation enumerated in 18 U.S.C. § 1028A(c), to wit: Conspiracy to Commit Wire Fraud
in violation of 18 U.S.C. §§ 1343 and 1349 as alleged in Count One, which is incorporated
herein by reference, knowing that the means of identification belonged to another actual person,
and aided and abetted each other in the same, in violation of 18 U.S.C.§§ 1028A and 2.
COUNT THREE
Conspiracy to Commit Interstate Communications with Intent to Extort and Cyberstalking
18 U.S.C. § 371
45. The allegations set forth in paragraphs 1 through 22 and 28 through 41 are hereby
realleged as if set forth herein.
46. From in or around November 2020 and continuing to in or around May 2023, the
exact dates being unknown to the Grand Jury, in the District of Idaho and elsewhere, the
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defendant, OLAMIDE OLADOSU SHANU, did combine, conspire, confederate, and agree with
others known and unknown to the Grand Jury, to commit offenses against the United States.
Objects of the Conspiracy
47. It was an object of the conspiracy, with intent to extort from victims, money and
other things of value, to transmit in interstate and foreign commerce communications containing
threats to injure the property and reputation of victims; to wit, to comunit sextortion against
victims, in violation of 18 U.S.C. §§875(d).
48, It was an object of the conspiracy, with the intent to harass and intimidate victims,
to use interactive computer services, electronic communication services, and electronic
communication systems of interstate commerce, and any other facility of interstate and foreign
commerce, to engage in a course of conduct that causes, attempts to cause, and would be
reasonably expected to cause substantial emotional distress to victims; fo wit, to commit
sextortion against victims, in violation of 18 U.S.C, § 2261 A(2)(B).
Manner and Means
49, To further the objects of the conspiracy, Defendant and his coconspirators, known
and unknown, carried out the manner and means described in paragraphs 28 through 41 of this
Indictment.
Overt Acts
50. To accomplish the objects of the conspiracy, the defendant, and his coconspirators
committed and caused to be committed the acts identified in Paragraphs 1 through 22 and 28
through 41 of this Indictment as well as the following overt acts, among others, in the District of
Idaho and elsewhere:
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Sl, On or about May 20, 2020, SHANU opened a Binance account with a deposit
address beginning with 1HYab (the “!HYab” address).
52, Onor about July 1, 2022, the coconspirators, using WhatsApp, instructed a victim
of the sextortion scheme (“V-5”) to make a payment as follows:
Tomorrow you gonna pay me 1500$ if you can pay me 1000$ mn. And we end everything
Deal!!!
53. Onot about April 3, 2023, Defendant and his coconspirators threatened CC-3 by
sending a screenshot of a draft post to Instagram that included CC-3’s explicit photos, provided
his home address and date of birth and stated the following:
Hello Fams this is [(CC-3)] naked pictures and dick he’s [((CC-3’s Username)} on
Instagram ...wew he tried to hurt me so I’m spreading his nudes rn to make him feel
ashamed all I want you guys to share this pictures all over the world till it toes viral and
get to all his friends and family that’s all.
Home Address: [redacted]
Date of birth: [redacted]
Age: 20
54. On or about May 2, 2023, Defendant and his coconspirators communicated with
V-1 using Snapchat and made multiple threatens to send V-1’s explicit images to his friends and
ruin his life unless V-1 made payments to a Venmo account controlled by CC-3.
55, On or about May 2, 2023, Defendant and his coconspirators caused V-1 to make
three payments totaling $1,000 to the Venmo account controlled by CC-3,
56. After receiving payments from V~-1, on or about May 5, 2023, CC-3 purchased
and transferred cryptocurrency to the address controlled by SHANU.
57. Qnor about the following dates, Defendant and his coconspirators caused victims
of the fraud schemes, including V-i, to send the following amounts, among others, to CC-3’s
Venmo account:
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58. Onor about the following dates, CC-3 purchased Bitcoin through bis CashApp
account and then sent the following Bitcoin payments through CashApp to two cryptocurrency
wallet addresses controlled by the coconspirators, including SHANU’s cryptocurrency wallet
TH Yab:
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All in violation of 18 U.S.C. § 373.
COUNT FOUR
Conspiracy to Commit Extortion
18 U.S.C. § 1951(a)
59, The allegations set forth in paragraphs 1 through 22 and 50 through 57 are hereby
realleged as if set forth herein.
60. From in or around November 2020 and continuing to in or around May 2023, the
exact dates being unknown to the Grand Jury, in the District of Idaho and elsewhere, the
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defendant, OLAMIDE OLADOSU SHANU, did combine, conspire, confederate, and agree with
others known and unknown to the Grand Jury to obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, and attempt to do so, by means of
extortion, as the terms “commerce” and “extortion" are defined in Title 18, U.S.C. §§ 1951(b)(2)
and (b)(3), in that the defendant and his coconspirators did combine, conspire, confederate, and
agree to engage in sextortion and thereby obtain property of victims, with the consent of the
victims induced by wrongful use of fear of economic and reputational harm.
Manner and Means
61. To further the objects of the conspiracy, Defendant and his coconspirators, known
and unknown, carried out the manner and means described in paragraphs 28 through 41 of this
Indictment.
All in violation of 18 U.S.C. § 195 1fa).
COUNT FIVE
Conspiracy to Commit Money Laundering
18 U.S.C. § 1956(h)
62. The allegations set for in paragraphs | through 22 and 50 through 57 are hereby
realleged as if set forth herein,
63. Beginning at least as early as in or around 2020, the exact date being unknown,
and continuing through in or about May 2023, in the District of Idaho and elsewhere, the
defendant, OLAMIDE OLADOSU SHANU, did combine, conspire, confederate, and agree with
others known and unknown to the Grand Jury, to commit money laundering offenses, in
violation of 18 U.S.C. § 1956 as follows:
a. to knowingly conduct, attempt to conduct, and aid and abet others to conduct,
financial transactions that affected interstate and foreign commerce, which
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involved the proceeds of specified unlawful activity, that is, sextortion proceeds
from Extortion, in violation of 18 U.S.C. § 1951(a), Interstate Communications
with Intent to Extort, in violation of 18 U.S.C. § 875(d), proceeds from Wire
Fraud, in violation of 18 U.S.C. § 1343, knowing that said transactions were
designed in whole or in part to conceal and disguise the nature, location, source,
ownership, and control of the proceeds of the specified unlawful activity, and that
while conducting such financial transactions, knew that the property involved in
the financial transactions represented the proceeds of some form of unlawful
activity, in violation of 18 U.S.C. § 1956(a)C1.)(B)G);
b. to transport, transmit, and transfer, and attempt to transport, transmit, and transfer,
and aid and abet others to transport, transmit, and transfer, monetary instruments
and funds involving the proceeds of specified unlawful activity, that is, sextortion
proceeds from Extortion, in violation of 18 U.S.C. § 195 I(a}, Interstate
Communications with Intent to Extort, in violation of 18 U.S.C, § 875(d), and
Cyberstalking, in violation of 18 U.S.C. § 2261 A(2)(B), and romance scam
proceeds from Wire Fraud, in violation of 18 U.S.C. § 1343, from places m the
United States to or through places outside the United States, knowing that the
monetary instruments and funds involved in the transportation, transmission, and
transfer represented the proceeds of some form of unlawful activity and knowing
that such transportation, transmission or transfer was designed in whole or in part
to conceal or disguise the nature and source of the proceeds of the unlawful
activity, in violation of 18 U.S.C. § 1956(a)(2)(B)@).
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Manner and Means
64. The allegations set forth in paragraphs 28 through 41 are realleged as if set forth
herein.
All in violation of 18 U.S.C. § 1956(h).
COUNT SIX
Extortion
18 U.S.C. § 1951(a)
65. The allegations set forth in paragraphs | through 11, 13 through 21, 50, and 53-56
are incorporated herein.
66, In or about May 2023, in the District of Idaho and elsewhere, 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, and
aided and abetted the same, to wit; committing sextortion against V-1 as described in paragraphs
through 11, 13 through 21, 50, and 53 through 56 above, in violation of 18 U.S.C. §§ 1951(a)
and 2,
COUNT SEVEN
Interstate Communication with Intent to Commit Extortion
18 U.S.C. § 875(d)
67. The allegations set forth in paragraphs 1 through 11, 13 through 21, 50, and 53
through 56 are incorporated herein.
68. Tn or about May 2023, in the District of Idaho and elsewhere, the Defendant,
OLAMIDE OLADOSU SHANU, with intent to extort from V-1 money and other things of
value, knowingly transmitted in interstate and foreign commerce communications containing
INDICTMENT - 18Page 19 threats to injure the property and reputation of V-1 through sextortion as described in 1 through
11, 13 through 21, 50, and 53 through 56 above, and aided and abetted the same, in violation of
18 U.S.C. §§ 875(d) and 2.
COUNT EIGHT
Cyberstatking
18 U.S.C. § 2261A(2)(B)
69. The allegations set forth in paragraphs | through 1, 13 through 21, 50, and 53
through 56 incorporated herein.
70. In or around May 2023, in the District of Idaho and elsewhere, the defendant,
OLAMIDE OLADOSU SHANU, with the intent to harass and intimidate V-1, used interactive
computer services, electronic communication services, and electronic communication systems of
interstate commerce, and other facilities of interstate and foreign commerce, to ehgage ina
course of conduct that caused, attempted to caused, and would be reasonably expected to cause
substantial emotional distress to V-1; to wit, to commit sextortion against V-1 as described in
paragraphs | through 11, 13 through 21, 50, and 53 through 56 above, and aided and abetted the
same, in violation of 18 U.S.C. §§ 2261A(2)(B) and 2.
CRIMINAL FORFEITURE ALLEGATION(S)
Fraud and Extortion Forfeiture
18 U.S.C. § 981(a)(1)(C)/28 U.S.C, § 2461(0)/18 U.S.C. § 982(a)
Upon conviction of the offenses alleged in Counts One and Four of this Indictment, the
Defendant, OLAMIDE OLADOSU SHANU, shall forfeit to the United States any and all
property, real and personal, tangible and intangible, consisting or derived from any proceeds the
said Defendant obtained directly or indirectly as a result of the foregoing offenses. The property
to be forfeited includes, but is not limited to, the following:
INDICTMENT - 19Page 20 Case 1:23-cr-00296-BLW Document4 Filed 11/14/23 Page 20 of 21
1, Unrecovered Cash Proceeds and/or Facilitating Property. Defendant obtained and
controlled unrecovered proceeds of the offense of conviction, or property derived from or
traceable to such proceeds, and property Defendant used to facilitate the offense, but based upon
actions of Defendant, the property was transferred, diminished, comingled, or is otherwise
unavailable. Defendant obtained and controlled at least $2,000,000 in unrecovered forfeitable
property.
2, Substitute Assets. Pursuant to 21 U.S.C. § 853(p) and other applicable statutes,
the government will seek forfeiture of substitute assets, “or any other property of Defendant” up
to the value of Defendant’s assets subject to forfeiture, The government will do so when the
property subject to forfeiture cannot be forfeited for one or more of the following reasons:
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.
Money Laundering Forfeiture
18 U.S.C. § 981(a)(1)(A), § 982(a)(1), and 28 U.S.C. § 2461(c).
34, The allegations contained in Count Five of this Indictment are hereby realleged
and incorporated by reference for the purpose of alleging forfeitures pursuant to 18 U.S.C, §
981(a)(1)(A), § 982(a)C1), and 28 U.S.C, § 2461 (c).
35. The United States hereby gives notice to the defendant, OLAMIDE OLADOSU
SHANU, that, upon his conviction of the money laundering offense in violation of 18 U.S.C. §
1956(h), as alleged in Count Five, OLAMIDE OLADOSU SHANU shall forfeit to the United
INDICTMENT - 20Page 21 Case 1:23-cr-00296-BLW Document4 Filed 11/14/23 Page 21 of 21
States of America, pursuant to 18 U.S.C. § 981(a)(1)(A), § 982(a)(1), and 28 U.S.C. § 2461(c),
any property, real or personal, involved in such offenses, and any property traceable to such
property.
36. Ifany of the property described above, as a result of any act or omission of the
Defendant:
a, Cannot be located upon the exercise of due diligence;
b.- Has been transferred or sold to, or deposited with, a third party;
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 divided without
difficulty,
the United States of America shall be entitled to forfeiture of substitute property pursuant to 21
U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461 (c).
Dated this 14th day of November 2023.
A TRUE BILL
/S/ [signature on reverse]
FOREPERSON
JOSHUA D. HURWIT
UNITED STATES ATTORNEY
ane | |
wey \ \ Ly
BRITTNEWCAMPBELL ”
SEAN M/MAZOROL
ASSISTANT UNITED STATES ATTORNEYS
INDICTMENT - 21
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PlainSite Cover Page
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Case 1:23-cr-00296-BLW Document4 Filed 11/14/23 Page 1 of 21
U.S. COURTS
JOSHUA D. HURWIT, IDAHO STATE BAR NO, 9527 NOV +4 2003
UNITED STATES ATTORNEY
BRITTNEY CAMPBELL, NORTH CAROLINA STATE BAR NO. 31433 — Reva Filad THC ecm"
ASSISTANT UNITED STATES ATTORNEY STEPHEN W, KENYON
SEAN M, MAZOROL, OREGON STATE BAR NO. 116398 CLERK, BISTRIGT GF IDAHO *
ASSISTANT UNITED STATES ATTORNEY
DISTRICT OF IDAHO
1290 W. MYRTLE ST, SUITE 500
BOISE, ID 83702-7788 ,
TELEPHONE: (208) 334-1211
FACSIMILE: (208) 334-1413
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF IDAHO
UNITED STATES OF AMERICA, Case No. Ca 3 3 _ q 3 9 é . G a
Plaintiff,
INDICTMENT
VS.
18 ULS.C, § 2
OLAMIDE OLADOSU SHANU, 18 US.C, § 371
18 U.S.C. § 875¢d)
Defendant. 18 ULS.C. § 981 (a) (A)
18 U.S.C. § 981 AKC)
18 U.S.C. § 982(a)
18 U.S.C. § 1028A
18 US.C. § 1343
18 U.S.C. § 1349
18 U.S.C. § 1951 (a)
18 U.S.C. § 1956(h)
18 U.S.C. § 2261A(2)
28 U.S.C. § 2461(c)
The Grand Jury charges:
At all times relevant to this Indictment:
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GENERAL ALLEGTIONS
1, OLAMIDE OLADOSU SHANU was a resident and national of Nigeria.
2. Unindicted coconspirator 1 (CC-1) was a resident and national of Nigeria.
3, Unindicted coconspirator 2 (CC-2) was a resident and national of Nigeria.
4, Unindicted coconspirator 3 (CC-3) was a resident of Michigan.
5, Unindicted coconspirator 4 (CC-4) was a resident of Oregon.
6. Victim-1 was a resident of Idaho and a student at a university in Idaho.
7, A “money mule,” as used in this Indictment, was a person who transfers illegally
acquired money on behalf of, and at the direction of, other individuals.
8. An “account takeover” as used in this Indictment, refers to theft and obtaining
control of another person’s legitimate pre-existing online account through fraudulent, deceptive,
or otherwise illegal means.
Overview of the Extortion and Fraud Schemes
9. From in or around November 2020 through in or around May 2023, the
defendant, SHANU and other coconspirators, known and unknown to the Grand Jury, were
engaged in a conspiracy to commit sextortion, romance scams, and other types of cyber-enabled
fraud schemes targeting individuals across the United States.
10. The schemes were typically organized, with coconspirators generally having
specific roles in the conspiracy. The coconspirators included “chatters,” such as CC-1 and CC-2,
who used fake social media accounts —or stolen social media accounts acquired via what is
known as “account takeover” —to target and seek out victims. In addition to establishing the
online “relationships” with the victims, the “chatters” provided the victims with the payment
demands and instructions about how and where to make the payments, Other coconspirators
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involved in the schemes managed the “chatters,” while other coconspirators, including SHANU,
primarily, but not exclusively, managed the funds obtained from the victims. United States
citizens, both unwitting and complicit and who were often victims themselves, including CC-3
and CC-4, were used as money mules to transfer funds through layered transactions to the
coconspirators,
11. The “sextortion” schemes were typically executed in a similar manner. The
coconspirators, posing as females, contacted victims, typically males, through social media using
fake accounts and taken-over accounts and persuaded the victims to send sexual images and/or
videos of themselves. Once the victims provided the explicit images and/or videos, the
coconspirators threatened to disseminate the images to the victims’ friends and family members
and/or to post them widely online unless the victim made payments to the coconspirators through
vatious peer-to-peer payment applications (““P2P Apps”), cryptocurrency transfers, and/or
through the purchase of gift cards. The coconspirators falsely assured the victims that if they
paid the demanded funds, the coconspirators would delete and/or refrain from distributing the
victims’ images.
12. The “romance scams” also followed a similar pattern. The coconspirators, using
fake identities on social media platforms, made contact with the victims and established
deceptive emotional relationships. The coconspirators gained the victims’ trust, persuaded the
victims first that they had a romantic future together and later that the coconspirators had urgent
needs for money, and then convinced the victims to send them money through P2P Apps, gift
cards, and/or eryptocurrency.
13. | SHANU and his coconspirators frequently used victims-turned-money mules to
receive and transmit the payments from the victims. Victims were instructed to make payments
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to the money mules using various P2P Apps stich as Venmo, Zelle, and CashApp. Frequently, as
directed by the coconspirators, the money mules then used the funds they received from the
victims to purchase and send cryptocurrency to wallet addresses provided by the coconspirators.
Other times, victims and money mules were instructed to purchase gift cards and transfer them to
the coconspirators.
14, SHANU and his coconspirators targeted numerous victims across the United
States, the exact number unknown to the Grand Jury, and from 2020 through 2023, Defendant
obtained at least $2 million in payments to a cryptocurrency address controlled by Defendant,
which was transferred offshore, including to multiple bank accounts in Nigeria.
Vietim-1
15. Coconspirators first made contact with Victim 1 (V-1), a student attending college
in Idaho, in May 2023, when an unknown “woman,” a coconspirator, began following V-1’s
account on the social media platform Instagram. Shortly after, V-1 and the unknown “woman”
began messaging on the social media platform Snapchat using the platform’s text chat function.
The unknown coconspirator used the Snapchat account “[female first name and last name with
initials C,W.]” (“Snapchat User 1”) to communicate with V-1 and appeared to be a white female
approximately 20-30 years of age. Snapchat User 1 sent V-1 what purported to be an explicit
photo of “herself” and persuaded V-1 to send an explicit photo of himself. When V-1 sent his
explicit photo, he was notified via the app that Snapchat User 1 had taken a screen capture of his
image that otherwise would have disappeared after a few moments.
16, Shortly after V-f sent his explicit image, on or about May 2, 2023, Snapchat User
1 sent V-1 a message using the Snapchat chat function and informed him, in substance, that if V-
1 did not follow Snapchat User i’s instructions, V-1’s explicit photo would be sent to everyone
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V-1 knew, all of his friends, and his life would be ruined. Along with this threat, Snapchat User
1 included a screenshot of what appeared to be a draft message in which an unknown person was
poised to send V-1’s explicit photo to his friends on Instagram.
17. Snapchat User 1 demanded a payment of $300 and provided V-1 with instructions
to send the payment to a Venmo account that belonged to CC-3. Snapchat User | also told V-1
that if he made the payment, then that would be the end of the extortion. After V-1 made the
initial $300 payment, Snapchat User 1 immediately made multiple additional demands for
payment. V-1 made an additional two payments which, along with his initial payment, totaled
$1,000. After making his third payment, the coconspirators demanded additional money. V-1
informed them that he would not make any additional payments.
18. After V-1 refused to make an additional payment, an unknown coconspirator
contacted V-1 using the Snapchat voice call function. The caller, who was male and spoke with
a strong accent, threatened V-1, and informed him that if he did not find a way to send additional
money then the caller would send V-1’s explicit photo to all of V-1’s friends. Despite the threat,
V-1 did not make additional payments, reported the fraud to Venmo, and blocked Snapchat User
1’s account.
19. V-1 was then contacted on Snapehat by a Snapchat account called [“C.S.96"]
(“Snapchat User 2”). Believing Snapchat User 2 to be the same individual as Snapchat User 1,
V-1 accepted Snapchat User 2’s friend request. Snapchat User 2 called V-1 using the Snapchat
voice call function. V-1 believed the voice was the same caller that had previously contacted
him and demanded payment. Snapchat User 2 questioned V-1 about reporting the fraud to
Venmo and again threatened to send V-I’s explicit photo to his friends unless he made additional
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payments, V-I refused to make any additional payments and, after blocking Snapehat User 2,
had no further contact with the coconspirators.
Coconspirators 1 through 4
20. Snapchat User 1 and Snapchat User 2 were both Snapchat accounts the
coconspirators fraudulently obtained from legitimate owners through account takeovers.
a, The “C.W.” account, used in the scheme by Snapchat User 1, was
originally owned by a female minor. 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 “C.W.”
b. The “C.S. 96” account, used by Snapchat User 2, was also owned by a
female minor. The account was taken over in or around April 2023. In executing the account
takeover, the coconspirators persuaded the original owner to change the recovery email address
to an address the coconspirators controlled. The coconspirators immediately changed the
password and took contro] of the account.
21. CC-3, the owner of the Venmo account that V-1 was instructed to pay, was also a
victim of the same sextortion scheme. Like V-1, CC-3 had been contacted by a coconspirator
posing as a young woman using names similar to the Snapchat User 1 and User 2 accounts. The
coconspirator persuaded CC-3 to send explicit images of himself. The coconspirator then
threatened to send CC-3’s explicit image to friends and families unless he paid $10,000. CC-3
agreed to pay $300 every week until he had paid the full amount. During this tune period, CC-3
was also coerced to serve as a money mule by receiving payments from other victims through his
Venmo account, The coconspirators directed CC-3 to purchase cryptocumency using the funds
he received from the other victims, including the funds he received from V-1, and then send the
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cryptocurrency to two wallet addresses the coconspirators controlled, including an address
owned by SHANU.
22, CC-4 was initially a victim of the romance fraud scheme. She believed she was in
a romantic relationship with an individual calling himself “Scott Bowman” (“Bowman”). In
addition to sending thousands of dollars of her own money to Bowman or to others at Bowman’s
behest, the coconspirators used CC-4 as a money mule, transmitting thousands of dollars from
victims to the coconspirators. Since 2020, CC-4 has sent a substantial amount of money to
SHANU’s 1HYab cryptocurrency wallet address, among others, She was also instructed to
purchase gift cards and conduct other financial transactions on behalf of the conspiracy.
COUNT ONE
Conspiracy to Commit Wire Fraud
18 U.S.C. §1349
23, The allegations set forth in paragraphs 1 through 22 are hereby realleged as if set
forth herein.
24. From in or around November 2020 and continuing to in or around May 2023, the
exact dates being unknown to the Grand Jury, in the District of Idaho and elsewhere, the
defendant, OLAMIDE OLADOSU SHANU, together with others known and unknown to the
Grand Jury, did knowingly and willfully combine, conspire, confederate, agree, and have a tacit
understanding with each other to devise and intend to devise schemes and artifices to defraud, as
to material matters, including sextortion, romance scams, and other cyber-enabled fraud
schemes, and fo obtain money and property, by means of materially false and fraudulent
pretenses, representations, and promises, and, in so doing, caused interstate and foreign wire
communications to be made, in furtherance of the schemes and artifices to defraud, in violation
of 18 U.S.C. § 1343,
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Object of the Conspiracy
25. It was a purpose of the conspiracy for the defendant, SHANU, and his
coconspirators to unlawfully enrich themselves by participating in a variety of cyber-enabled
fraud schemes, including sextortion and romance scams, that targeted individuals throughout the
United States.
Manner and Means
26. To further the objects of the conspiracy, Defendant and his coconspirators, known
and unknown, used the following manner and means, among others:
27. Defendant and his coconspirators engaged in account takeovers and creation of
fake social media accounts.
28. Defendant and his coconspirators utilized interstate and foreign wires to (1)
contact victims through various social media platforms including Snapshat and Instagram, (2)
communicate with victims using WhatsApp; (3) obtain payments from victims using various P2P
payment apps such as Venmo and CashApp; and (4) cause victims and money mules to purchase
and transfer cryptocurrency to various addresses in hosted and un-hosted cryptocurrency wallets.
29, Defendant and his coconspirators contacted victims of the sextortion schemes
using the fake and stolen social media accounts posing primarily as young females.
30, Defendant and his coconspirators convinced victims to send them explicit images
and videos.
31. Defendant and his coconspirators threatened to send the explicit images and
videos to friends and family of the victims unless the victims made payment to Defendant and
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his coconspirators. The coconspirators used and shared a common written “script” of how to
make threats and extort money from victims, including, but not limited, to the following:
32,
Hey I have ur nudes and everything needed to ruin your life, 1 have
screenshot all ur followers and tags and those that comment on ur
post. I can send this nudes to everyone in your city till it go virals
or send this all females on your list and your family if u don’t
cooperate..,.all u have to do is to cooperate with me and i will not
expose u, if u block me i will ruin your life
FOR THE FACEBOOK POSTING
Hello famz this is [name of victim] naked pictures and dick he’s
[(victim user name)] on Instagram...he tried to hurt me so ’'m
spreading his nudes m to make him feel ashamed all i want you
guys to share this pictures all over the world till it goes viral and get
to ail his friends and family that’s all.
Ul
I’ve been doing this for years now
Over 10 years,,J’ve done this to lot of cops and top people in the
state and as soon as they do what I want I let them go cuz I always
do as I’ve promised
And when they try to prove stubborn with me... expose them like I
do promise and when that happens it ruin their career, their
relationship, their family get shattered and they lose other
opportunities too
Defendant and his coconspirators made materially false and fraudulent pretenses,
representations, and promises to the sextortion victims to obtain money and property from the
victim, including falsely telling the victims that if they paid the specific amount initially
demanded, then the sextortion would end.
33.
Defendant and his coconspirators adopted fake online identities and
communicated with victims of the romance scams to gain the affection and trust of individuals.
34,
Defendant and his coconspirators initiated contact with the victims of the romance
scams by sending victims emails, text messages, and messages through online dating and social
*
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media websites that deceived the victims into believing they were in relationships with a person
who was, in fact, a fake identity assumed by the coconspirators.
35, Defendant and his coconspirators convinced the romance scam victims, under
false representations, promises, and/or pretenses, to transfer money and payments to the
coconspirators.
36. Defendant and his coconspirators made materially false and fraudulent pretenses,
representations, and promises, of a romantic and close relationship to obtain money and property
from the romance scam victims,
37, Defendant and his coconspirators caused the victims of the sextortion and
romance scams to transmit money and property by means of wire communication in interstate
and foreign commerce to Defendant and his coconspirators.
38. Defendant and his coconspirators caused the victims of the sextortion and
romance scams to send payments to cryptocurrency addresses controlled by Defendant and his
coconspirators.
39, Defendant and his coconspirators coerced and manipulated victims of sextortion
and romance scams to act as money mules for the sextortion, romance scams, and other cyber-
enabled fraud.
40. Defendant and his coconspirators used the money mules to receive the payments
from the fraud victims, typically via P2P payment apps, and then launder the fraud proceeds by
converting those proceeds to cryptocurrency and sending to addresses provided and controlled by
Defendant and his coconspirators, known and unknown.
41. Defendant and his conspirators also instructed the money mules to purchase gift
cards and provide the cards and/or card information to the coconspirators.
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42. Defendant and his coconspirators frequently sold the cryptocurrency through one
ot more cryptocurrency exchanges and deposited the funds into multiple bank accounts primarily
located in Nigeria.
Allin violation of 18 U.S.C, § 1349.
COUNT TWO
Aggravated Identity Theft
18 U.S.C. § 1028A
43. The allegations set forth in paragraphs | through 22 and 28 through 41 are hereby
realleged as if set forth herein.
44, Beginning in or around February 2023 through in or around April 2023, in the
District of Idaho and elsewhere, the defendant, OLAMIDE OLADOSU SHANU, and his
coconspirators, known and unknown to the Grand Jury, without lawful authority, did knowingly
possess, transfer, and use, a means of identification of another person, during and in relation to a
felony violation enumerated in 18 U.S.C. § 1028A(c), to wit: Conspiracy to Commit Wire Fraud
in violation of 18 U.S.C. §§ 1343 and 1349 as alleged in Count One, which is incorporated
herein by reference, knowing that the means of identification belonged to another actual person,
and aided and abetted each other in the same, in violation of 18 U.S.C.§§ 1028A and 2.
COUNT THREE
Conspiracy to Commit Interstate Communications with Intent to Extort and Cyberstalking
18 U.S.C. § 371
45. The allegations set forth in paragraphs 1 through 22 and 28 through 41 are hereby
realleged as if set forth herein.
46. From in or around November 2020 and continuing to in or around May 2023, the
exact dates being unknown to the Grand Jury, in the District of Idaho and elsewhere, the
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defendant, OLAMIDE OLADOSU SHANU, did combine, conspire, confederate, and agree with
others known and unknown to the Grand Jury, to commit offenses against the United States.
Objects of the Conspiracy
47. It was an object of the conspiracy, with intent to extort from victims, money and
other things of value, to transmit in interstate and foreign commerce communications containing
threats to injure the property and reputation of victims; to wit, to comunit sextortion against
victims, in violation of 18 U.S.C. §§875(d).
48, It was an object of the conspiracy, with the intent to harass and intimidate victims,
to use interactive computer services, electronic communication services, and electronic
communication systems of interstate commerce, and any other facility of interstate and foreign
commerce, to engage in a course of conduct that causes, attempts to cause, and would be
reasonably expected to cause substantial emotional distress to victims; fo wit, to commit
sextortion against victims, in violation of 18 U.S.C, § 2261 A(2)(B).
Manner and Means
49, To further the objects of the conspiracy, Defendant and his coconspirators, known
and unknown, carried out the manner and means described in paragraphs 28 through 41 of this
Indictment.
Overt Acts
50. To accomplish the objects of the conspiracy, the defendant, and his coconspirators
committed and caused to be committed the acts identified in Paragraphs 1 through 22 and 28
through 41 of this Indictment as well as the following overt acts, among others, in the District of
Idaho and elsewhere:
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Sl, On or about May 20, 2020, SHANU opened a Binance account with a deposit
address beginning with 1HYab (the “!HYab” address).
52, Onor about July 1, 2022, the coconspirators, using WhatsApp, instructed a victim
of the sextortion scheme (“V-5”) to make a payment as follows:
Tomorrow you gonna pay me 1500$ if you can pay me 1000$ mn. And we end everything
Deal!!!
53. Onot about April 3, 2023, Defendant and his coconspirators threatened CC-3 by
sending a screenshot of a draft post to Instagram that included CC-3’s explicit photos, provided
his home address and date of birth and stated the following:
Hello Fams this is [(CC-3)] naked pictures and dick he’s [((CC-3’s Username)} on
Instagram ...wew he tried to hurt me so I’m spreading his nudes rn to make him feel
ashamed all I want you guys to share this pictures all over the world till it toes viral and
get to all his friends and family that’s all.
Home Address: [redacted]
Date of birth: [redacted]
Age: 20
54. On or about May 2, 2023, Defendant and his coconspirators communicated with
V-1 using Snapchat and made multiple threatens to send V-1’s explicit images to his friends and
ruin his life unless V-1 made payments to a Venmo account controlled by CC-3.
55, On or about May 2, 2023, Defendant and his coconspirators caused V-1 to make
three payments totaling $1,000 to the Venmo account controlled by CC-3,
56. After receiving payments from V~-1, on or about May 5, 2023, CC-3 purchased
and transferred cryptocurrency to the address controlled by SHANU.
57. Qnor about the following dates, Defendant and his coconspirators caused victims
of the fraud schemes, including V-i, to send the following amounts, among others, to CC-3’s
Venmo account:
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Date | Vietim = | Approx. Amount ~
4-15-2023 V-2 $1500
4-24-2023 V-3 $250
5-02-2023 V-1 $1,000
5-02-2023 V-4 $495
58. Onor about the following dates, CC-3 purchased Bitcoin through bis CashApp
account and then sent the following Bitcoin payments through CashApp to two cryptocurrency
wallet addresses controlled by the coconspirators, including SHANU’s cryptocurrency wallet
TH Yab:
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Date Approx. Amount | Approx. BTC Transferred (less fee)
of USD Sold Amount of to External] Wallet
BTC Addresses
Purchased
4-04-2023 | $48.88 BTC IHYab
0.00173263
4-06-2023 | $392.99 BTC LHYab
0.01403366
4-09-2023 | $294.74 BTC belq
0.01053267
4-14-2023 | $304.58 BTC belg
0,00987582
4-15-2023 | $1522.81 BTC belq and 1HYab
0.04999801
4-17-2023 | $177.37 BTC 1HYab
0.00593494
4-21-2023 | $491.24 BTC tHYab
0.01746379
04-24-2023 | $240.70 BIC 1HYab
0.00867588
4-28-2023 | $294.74 BTC 1HYab
0,.01008518
4-28-2023 | $24.44 BTC 1HYab
0,00083700
5-02-2023 | $1403.50 BTC 1HY¥ab
0.05003235
5-02-2023 | $915.65 BTC 1HYab
0.03264763
5-05-2023 | $491.22 BTC 1HYab
0.01684573
All in violation of 18 U.S.C. § 373.
COUNT FOUR
Conspiracy to Commit Extortion
18 U.S.C. § 1951(a)
59, The allegations set forth in paragraphs 1 through 22 and 50 through 57 are hereby
realleged as if set forth herein.
60. From in or around November 2020 and continuing to in or around May 2023, the
exact dates being unknown to the Grand Jury, in the District of Idaho and elsewhere, the
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defendant, OLAMIDE OLADOSU SHANU, did combine, conspire, confederate, and agree with
others known and unknown to the Grand Jury to obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, and attempt to do so, by means of
extortion, as the terms “commerce” and “extortion" are defined in Title 18, U.S.C. §§ 1951(b)(2)
and (b)(3), in that the defendant and his coconspirators did combine, conspire, confederate, and
agree to engage in sextortion and thereby obtain property of victims, with the consent of the
victims induced by wrongful use of fear of economic and reputational harm.
Manner and Means
61. To further the objects of the conspiracy, Defendant and his coconspirators, known
and unknown, carried out the manner and means described in paragraphs 28 through 41 of this
Indictment.
All in violation of 18 U.S.C. § 195 1fa).
COUNT FIVE
Conspiracy to Commit Money Laundering
18 U.S.C. § 1956(h)
62. The allegations set for in paragraphs | through 22 and 50 through 57 are hereby
realleged as if set forth herein,
63. Beginning at least as early as in or around 2020, the exact date being unknown,
and continuing through in or about May 2023, in the District of Idaho and elsewhere, the
defendant, OLAMIDE OLADOSU SHANU, did combine, conspire, confederate, and agree with
others known and unknown to the Grand Jury, to commit money laundering offenses, in
violation of 18 U.S.C. § 1956 as follows:
a. to knowingly conduct, attempt to conduct, and aid and abet others to conduct,
financial transactions that affected interstate and foreign commerce, which
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involved the proceeds of specified unlawful activity, that is, sextortion proceeds
from Extortion, in violation of 18 U.S.C. § 1951(a), Interstate Communications
with Intent to Extort, in violation of 18 U.S.C. § 875(d), proceeds from Wire
Fraud, in violation of 18 U.S.C. § 1343, knowing that said transactions were
designed in whole or in part to conceal and disguise the nature, location, source,
ownership, and control of the proceeds of the specified unlawful activity, and that
while conducting such financial transactions, knew that the property involved in
the financial transactions represented the proceeds of some form of unlawful
activity, in violation of 18 U.S.C. § 1956(a)C1.)(B)G);
b. to transport, transmit, and transfer, and attempt to transport, transmit, and transfer,
and aid and abet others to transport, transmit, and transfer, monetary instruments
and funds involving the proceeds of specified unlawful activity, that is, sextortion
proceeds from Extortion, in violation of 18 U.S.C. § 195 I(a}, Interstate
Communications with Intent to Extort, in violation of 18 U.S.C, § 875(d), and
Cyberstalking, in violation of 18 U.S.C. § 2261 A(2)(B), and romance scam
proceeds from Wire Fraud, in violation of 18 U.S.C. § 1343, from places m the
United States to or through places outside the United States, knowing that the
monetary instruments and funds involved in the transportation, transmission, and
transfer represented the proceeds of some form of unlawful activity and knowing
that such transportation, transmission or transfer was designed in whole or in part
to conceal or disguise the nature and source of the proceeds of the unlawful
activity, in violation of 18 U.S.C. § 1956(a)(2)(B)@).
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Manner and Means
64. The allegations set forth in paragraphs 28 through 41 are realleged as if set forth
herein.
All in violation of 18 U.S.C. § 1956(h).
COUNT SIX
Extortion
18 U.S.C. § 1951(a)
65. The allegations set forth in paragraphs | through 11, 13 through 21, 50, and 53-56
are incorporated herein.
66, In or about May 2023, in the District of Idaho and elsewhere, 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, and
aided and abetted the same, to wit; committing sextortion against V-1 as described in paragraphs
1 through 11, 13 through 21, 50, and 53 through 56 above, in violation of 18 U.S.C. §§ 1951(a)
and 2,
COUNT SEVEN
Interstate Communication with Intent to Commit Extortion
18 U.S.C. § 875(d)
67. The allegations set forth in paragraphs 1 through 11, 13 through 21, 50, and 53
through 56 are incorporated herein.
68. Tn or about May 2023, in the District of Idaho and elsewhere, the Defendant,
OLAMIDE OLADOSU SHANU, with intent to extort from V-1 money and other things of
value, knowingly transmitted in interstate and foreign commerce communications containing
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threats to injure the property and reputation of V-1 through sextortion as described in 1 through
11, 13 through 21, 50, and 53 through 56 above, and aided and abetted the same, in violation of
18 U.S.C. §§ 875(d) and 2.
COUNT EIGHT
Cyberstatking
18 U.S.C. § 2261A(2)(B)
69. The allegations set forth in paragraphs | through 1, 13 through 21, 50, and 53
through 56 incorporated herein.
70. In or around May 2023, in the District of Idaho and elsewhere, the defendant,
OLAMIDE OLADOSU SHANU, with the intent to harass and intimidate V-1, used interactive
computer services, electronic communication services, and electronic communication systems of
interstate commerce, and other facilities of interstate and foreign commerce, to ehgage ina
course of conduct that caused, attempted to caused, and would be reasonably expected to cause
substantial emotional distress to V-1; to wit, to commit sextortion against V-1 as described in
paragraphs | through 11, 13 through 21, 50, and 53 through 56 above, and aided and abetted the
same, in violation of 18 U.S.C. §§ 2261A(2)(B) and 2.
CRIMINAL FORFEITURE ALLEGATION(S)
Fraud and Extortion Forfeiture
18 U.S.C. § 981(a)(1)(C)/28 U.S.C, § 2461(0)/18 U.S.C. § 982(a)
Upon conviction of the offenses alleged in Counts One and Four of this Indictment, the
Defendant, OLAMIDE OLADOSU SHANU, shall forfeit to the United States any and all
property, real and personal, tangible and intangible, consisting or derived from any proceeds the
said Defendant obtained directly or indirectly as a result of the foregoing offenses. The property
to be forfeited includes, but is not limited to, the following:
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1, Unrecovered Cash Proceeds and/or Facilitating Property. Defendant obtained and
controlled unrecovered proceeds of the offense of conviction, or property derived from or
traceable to such proceeds, and property Defendant used to facilitate the offense, but based upon
actions of Defendant, the property was transferred, diminished, comingled, or is otherwise
unavailable. Defendant obtained and controlled at least $2,000,000 in unrecovered forfeitable
property.
2, Substitute Assets. Pursuant to 21 U.S.C. § 853(p) and other applicable statutes,
the government will seek forfeiture of substitute assets, “or any other property of Defendant” up
to the value of Defendant’s assets subject to forfeiture, The government will do so when the
property subject to forfeiture cannot be forfeited for one or more of the following reasons:
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.
Money Laundering Forfeiture
18 U.S.C. § 981(a)(1)(A), § 982(a)(1), and 28 U.S.C. § 2461(c).
34, The allegations contained in Count Five of this Indictment are hereby realleged
and incorporated by reference for the purpose of alleging forfeitures pursuant to 18 U.S.C, §
981(a)(1)(A), § 982(a)C1), and 28 U.S.C, § 2461 (c).
35. The United States hereby gives notice to the defendant, OLAMIDE OLADOSU
SHANU, that, upon his conviction of the money laundering offense in violation of 18 U.S.C. §
1956(h), as alleged in Count Five, OLAMIDE OLADOSU SHANU shall forfeit to the United
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States of America, pursuant to 18 U.S.C. § 981(a)(1)(A), § 982(a)(1), and 28 U.S.C. § 2461(c),
any property, real or personal, involved in such offenses, and any property traceable to such
property.
36. Ifany of the property described above, as a result of any act or omission of the
Defendant:
a, Cannot be located upon the exercise of due diligence;
b.- Has been transferred or sold to, or deposited with, a third party;
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 divided without
difficulty,
the United States of America shall be entitled to forfeiture of substitute property pursuant to 21
U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461 (c).
Dated this 14th day of November 2023.
A TRUE BILL
/S/ [signature on reverse]
FOREPERSON
JOSHUA D. HURWIT
UNITED STATES ATTORNEY
ane | |
wey \ \ Ly
BRITTNEWCAMPBELL ”
SEAN M/MAZOROL
ASSISTANT UNITED STATES ATTORNEYS
INDICTMENT - 21
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