UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -x UNITED STATES OF AMERICA - v. SEALED INDICTMENT - ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, STAN GREENBERG, a/k/a "Slava," ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," JOHN HANSON, NOAH SIEGEL, a/k/a "The Oracle," JONATHAN HIRSCH, ARTHUR AZEN, DONALD MCCALMONT, DMITRY DRUZHINSKY, a/k/a "Dima," a/k/a "Blondie," ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a "Murushka," ANATOLY SHTEYNGROB, a/k/a "Tony," ILYA ROZENFELD, PETER SKYLLAS, RONALD UY, NICHOLAS HIRSCH, BRYAN ZURIFF, MOSHE ORATZ, KIRILL RAPOPORT, DAVID AARON, a/k/a "D.A.," JUSTIN SMITH, ABRAHAM MOSSERI, 13 Cr. - 1 - WILLIAM EDLER, PETER FELDMAN, EUGENE TRINCHER, EDWIN TING, a/k/a "Eddie," MOLLY BLOOM, WILLIAM BARBALAT, YUGESHWAR RAJ KUMAR , a/k/a "Mateo Hermatte, " and JOSEPH MANCUSO, a/k/a "Joe the Hammer," Defendants. - - - - - - - - - - - - - - - - - -x COUNT ONE (Racketeering Conspiracy: Taiwanchik-Trincher Organization) The Grand Jury charges: The Enterprise 1. At all times relevant to this Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, and others known and unknown, were members and associates of the "Taiwanchik-Trincher Organization." The Taiwanchik-Trincher Organization was a criminal organization whose members and associates engaged in crimes including operating an illegal gambling business, money laundering, and extortion. 2. The Taiwanchik-Trincher Organization, including its leadership, membership, and associates, constituted an - 2 - "enterprise," as that term is defined in Title 18, United States Code, Section 1961(4) associated in fact. -- that is, a group of individuals This enterprise was engaged in, and its activities affected, interstate and foreign commerce. The Taiwanchik-Trincher Organization was an international organized crime group with leadership based in New York City, Kiev, and Moscow, and that operated throughout the United States, including in the Southern District of New York, and internationally. The Taiwanchik-Trincher Organization constituted an ongoing organization whose members functioned as a continuing unit for a common purpose of aChieving the objectives of the enterprise. 3. Most members and associates of the Taiwanchik- Trincher Organization were born in the former Soviet Union and many maintained substantial ties to Ukraine and the Russian Federation, including regular travel to Ukraine and the Russian Federation, criminal connections to individuals residing in Ukraine and the Russian Federation, the transfer of criminal proceeds to and from Ukraine and the Russian Federation, the purchase of real estate and other assets in Ukraine and the Russian Federation with criminal proceeds, and the operation of an international gambling business in Ukraine and the former Soviet union. - 3 - 4. The Taiwanchik-Trincher Organization was led principally by three individuals: ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants. 5. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," the defendant, who lived in the Russia Federation, was a "vory v zakone," commonly referred to as "Vor" -- a Russian term translated as "Thief-in-Law" and referring to a member of a select group of the highest-level criminal figures from the former Soviet Union who receives tribute from other criminals, offers protection, and uses his recognized position of authority to resolve disputes among criminals. As a Vor, TOKHTAKHOUNOV had substantial influence in the criminal underworld and offered assistance to and protection of the Taiwanchik-Trincher Organization. 6. The two other leaders of the Taiwanchik-Trincher Organization, VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, were based in New York City. TRINCHER and GOLUBCHIK were the principal, though not exclusive, leaders of the Taiwanchik-Trincher Organization's criminal conduct and ventures, which included an illegal gambling business, money laundering, extortion, and other crimes. TRINCHERand GOLUBCHIK were assisted by numerous - 4 - criminal partners and associates throughout the United States, Ukraine, the Russian Federation, and elsewhere. The Defendants 7. Vor ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," the defendant, was a powerful figure in former Soviet Union organized crime. TOKHTAKHOUNOV rarely left the former Soviet Union because he was under indictment by the United States Attorney's Office for the Southern District of New York on charges related to his role in allegedly bribing officials at the 2002 Winter Olympic Games in Salt Lake City, Utah. TOKHTAKHOUNOV was a participant in the enterprise, the Taiwanchik-Trincher Organization, and was a leader of it. TOKHTAKOUNOV used his status as a Vor to resolve disputes with clients of the high-stakes illegal gambling operation with implicit and sometimes explicit threats of violence and economic harm. From in or around December 2011 through in or about January 2012, TOKHTAKOUNOV was paid $10,000,000 by the Taiwanchik-Trincher Organization. 8. VADIM TRINCHER, a/k/a "Dima," the defendant, was a participant in the enterprise, the Taiwanchik-Trincher Organization, and was a leader of it. In that capacity, TRINCHER participated in and profited from various crimes, which he committed along with other members and associates of the Taiwanchik-Trincher Organization. - 5 - Among other things, TRINCHER oversaw a high-stakes illegal sports gambling business that catered almost exclusively to oligarchs living in Ukraine and the Russian Federation. 9. ANATOLY GOLUBCHIK, a/k/a "Tony," the defendant, was a participant in the enterprise, the Taiwanchik-Trincher Organization, and was a leader of the enterprise. In that capacity, GOLUBCHIK participated in and profited from various crimes, which he committed along with other members and associates of the Taiwanchik-Trincher Organization. Among other things, GOLUBCHIK worked with TRINCHER to oversee the sports gambling business and directed members and associates of the Taiwanchik-Trincher Organization in laundering tens of millions of dollars of profits from that business. 10. MICHAEL SALL and STAN GREENBERG, a/k/a "Slava," the defendants, were United States-based participants in the enterprise, the Taiwanchik-Trincher Organization. In this capacity, these defendants participated in and profited from various crimes, including money laundering, which they committed along with other members and associates of the TaiwanchikTrincher Organization. Purposes of the Enterprise 11. The purposes of the enterprise included the following: - 6 - a. enriching the leaders, members, and associates of the enterprise through an illegal gambling business, money laundering, extortion, and other crimes; b. preserving and augmenting the power, territory, and financial profits of the enterprise through intimidation, violence, and threats of physical and economic harm; and c. avoiding detection of their illegal conduct in order to continue to enrich themselves. Means and Methods of the Enterprise 12. Among the means and methods by which ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, and their coconspirators, and other members and associates conducted and participated in the conduct of the affairs of the TaiwanchikTrincher Organization were the following: a. Members and associates of the Taiwanchik- Trincher Organization and their co-conspirators worked together on a range of criminal money-making schemes, including operating an international gambling business that catered to oligarchs residing in the former Soviet Union and throughout the world. - 7 - b. Members and associates of the Taiwanchik- Trincher Organization and their co-conspirators used threats of violence to obtain unpaid gambling debts from clients. c. Members and associates of the Taiwanchik- Trincher Organization and their co-conspirators employed a sophisticated money laundering scheme to move tens of millions of dollars in proceeds from the gambling operation from the former Soviet Union through shell companies in Cyprus into various investments and other shell companies in the United States. The Racketeering Conspiracy 13. From at least in or about 2006, up to and including on or about the date of this Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, and others known and unknown, in the Southern District of New York and elsewhere, being persons employed by and associated with the racketeering enterprise described in paragraphs 1 through 12 above, namely, the Taiwanchik-Trincher Organization, which enterprise was engaged in, and the activities of which affected, interstate and foreign commerce, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to violate Title 18, United States Code, Section 1962(c), to wit, to - 8 - conduct and participate, directly and indirectly, in the conduct of such enterprise's affairs through a pattern of racketeering activity, as those terms are defined in Title 18, United States Code, Sections 1961(1) and 1961(5), and as set forth below in paragraph 14. It was further a part of the conspiracy that the defendants agreed that a conspirator would commit at least two acts of racketeering activity in the conduct of the affairs of the enterprise. The Pattern of Racketeering 14. The pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, and their co-conspirators agreed to conduct and participate in the conduct of the affairs of the enterprise consisted of multiple acts indictable under the following federal and state statutes: a. Title 18, United States Code, Section 1955 (operating an illegal gambling business) ; b. Title 18, United States Code, Section 1951 (interference with commerce by threats and violence) ; c. and 1957 Title 18, United States Code, Sections 1956 (money laundering) ; - 9 - d. Title 18, United States Code, Section 1084 (transmission of wagering information), e. Title 18, United States Code, Section 1952 (interstate and foreign travel and transportation in aid of racketeering enterprises) i f. Title 18, United States Code, Section 894 (collection of extensions of credit by extortionate means) i and g. Multiple acts involving gambling, in violation of New York Penal Law Section 225.10. It was further a part of the conspiracy that the defendants agreed that a conspirator would commit at least two acts of racketeering activity in the conduct of the affairs of the enterprise. (Title 18, United States Code, Section 1962(d).) COUNT TWO (Racketeering: Taiwanchik-Trincher Organization) The Grand Jury further charges: 15. The allegations contained in paragraphs 1 through 12 above are hereby repeated, realleged, and incorporated by reference herein as though fully set forth at length for the purpose of alleging Count Two of this Indictment. 16. From at least in or about 2006, up to and including on or about the date of this Indictment, ALIMZHAN - 10 - TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, and others known and unknown, in the Southern District of New York and elsewhere, being persons employed by and associated with the racketeering enterprise described in paragraphs 1 through 12 above, namely, the Taiwanchik-Trincher Organization, which enterprise was engaged in, and the activities of which affected, interstate and foreign commerce, willfully and knowingly did conduct and participate, directly and indirectly, in the conduct of such enterprise's affairs through a pattern of racketeering activity as set forth below in paragraphs 17 through 24. The Pattern of Racketeering 17. The pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), consisted of the following acts: Racketeering Act One: 18. Illegal Gambling Business ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, supervised an international bookmaking operation that catered primarily to oligarchs located in the former Soviet Union and throughout the world. The defendants committed the following acts, anyone of which alone constitutes the commission of Racketeering Act One: - 11 - I a. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, knowingly and willfully did conduct, finance, manage, supervise, direct, and own all and part of an illegal gambling business, as that term is defined in Title 18, United States Code, Section 1955 (b) (1), (2), and (3), to wit, the defendants operated a bookmaking business that violated New York Penal Law 225.10, involved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part of such business, and had been and remained in substantially continuous operation for a period in excess of thirty days and had a gross revenue of $2,000 in any single day, in violation of Title 18, United States Code, Section 1955(a). b. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, knowingly and willfully did advance and profit from unlawful gambling activity by engaging in bookmaking to the extent that they received and accepted in anyone day more than - 12 - five bets totaling more than $5,000, in violation of New York Penal Law section 225.10. c. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, being engaged in the business of betting and wagering, knowingly and willfully did use a wire communication facility for the transmission in interstate and foreign commerce of bets and wagers and information assisting in the placing of bets and wagers on sporting events and contests, and for the transmission of wire communications which entitled the recipient to receive money and credit as a result of bets and wagers, and for information assisting in the placing of bets and wagers, in violation of Title 18, United States Code, Section 1084. Racketeering Act Two: 19. Extortion Conspiracy ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, committed the following acts, any one of which alone constitutes the commission of Racketeering Act Two: a. From at least in or about 2006, up to and including on or about the date of this Indictment, in the - 13 - Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to commit extortion, as that term is defined in Title 18, United States Code, Section 1951 (b) (2), by obtaining money and property from and with the consent of another person, to wit, clients of their illegal gambling business, which consent was and would have been induced by the wrongful use of actual and threatened force, violence and fear, and thereby would and did obstruct, delay, and affect commerce and the movement of articles and commodities in commerce, as that term is defined in Title 18, United States Code, Section 1951(b) (3), in violation of Title 18, United States Code, Section 1951. b. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to participate in the use of extortionate - 14 - means, as that term is defined in Title 18, United States Code, Section 891(7), to collect and attempt to collect extensions of credit, as that term is defined in Title 18, United States Code, Section 891(1), and to punish persons, to wit, clients of their illegal gambling business, for the nonrepayment thereof, in violation of Title 18, United States Code, Section 894. Racketeering Act Three: 20. Extortion of Client-1 ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," the defendant, committed the following acts, anyone of which alone constitutes the commission of Racketeering Act Three: a. In or about May 2012, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," the defendant, and others known and unknown, willfully and knowingly did commit and attempt to commit extortion, and aid and abet the commission of extortion, as that term is defined in Title 18, United States Code, Section 1951(b) (2), by attempting to obtain and obtaining money and property from and with the consent of "Client-I," a client of the enterprise's illegal gambling business, whose consent was induced by the wrongful use of actual and threatened force, violence, and fear, and thereby attempted to and did obstruct, delay, and affect commerce, as that term is defined in - 15 - Title 18, United States Code, Section 1951(b) (3), in violation of Title 18, United States Code, Sections 1951 and 2. b. In or about May 2012, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," the defendant, and others known and unknown, willfully and knowingly did participate in the use of extortionate means, as that term is defined in Title 18, United States Code, Section 891(7), to collect and attempt to collect extensions of credit, as that term is defined in Title 18, United States Code, Section 891(1), and to punish a person, to wit, Client-1, for the nonrepayment thereof, in violation of Title 18, United States Code, Section 894. Racketeering Act Four: 21. Extortion of Client-2 VADIM TRINCHER, a/k/a "Dima," the defendant, committed the following acts, anyone of which alone constitutes the commission of Racketeering Act Four: a. In or about February 2012, in the Southern District of New York and elsewhere, VADIM TRINCHER, a/k/a "Dima," the defendant, and others known and unknown, willfully and knowingly did commit and attempt to commit extortion, and aid and abet the commission of extortion, as that term is defined in Title 18, United States Code, Section 1951(b) (2), by attempting to obtain and obtaining money and property from and with the consent of "Client-2," a client of the enterprise's - 16 - illegal gambling business, whose consent was induced by the wrongful use of actual and threatened force, violence, and fear, and thereby attempted to and did obstruct, delay, and affect commerce, as that term is defined in Title 18, united States Code, Section 1951 (b) (3), in violation of Title 18, united States Code, Sections 1951 and 2. b. In or about February 2012, in the Southern District of New York and elsewhere, VADIM TRINCHER, a/k/a "Dima," the defendant, and others known and unknown, willfully and knowingly did participate in the use of extortionate means, as that term is defined in Title 18, United States Code, Section 891(7), to collect and attempt to collect extensions of credit, as that term is defined in Title 18, United States Code, Section 891(1), and to punish a person, to wit, Client-2, for the nonrepayment thereof, in violation of Title 18, United States Code, Section 894. Racketeering Act Five: 22. Money Laundering Conspiracy ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, participated in a sophisticated international scheme to launder tens of millions of dollars in proceeds from their illegal gambling business through bank accounts and shell companies in Cyprus, including from the Russia Federation to Cyprus and then back to the Russian - 17 - Federation and from the Russian Federation to Cyprus and then l to the United States. a. From at least in or about 2006 including on or about the date of this Indictment Southern District of New York and elsewhere l I up to and 1 in the ALIMZHAN TOKHTAKHOUN"OV I a/k/a "Taiwanchik l ll a/k/a "Aliklll VADIM TRINCHER I a/k/a "Dima l II defendants and others known and unknown I and ANATOLY GOLUBCHIK I a/k/a "Tonylll the knowingly combined l conspired I willfully and I confederated I and agreed together and with each other to violate Sections 1956 (a) (1) (B) (i) (a) (2) (A) I and (a) (2) (B) (i) I and 1957 of Title 18 1 I United States Code. b. It was a part and an object of the conspiracy that ALIMZHAN TOKHTAKHOUNOV I a/k/a "Taiwanchik a/k/a "Alik l II VADIM TRINCHER I a/k/a "Dima l GOLUBCHIK I a/k/ a "Tony unknown I I II the defendants I II ll l and ANATOLY and others known and knowing that the property involved in financial transactions represented the proceeds of some form of unlawful activitYI willfully and knowingly would and did conduct and attempt to conduct financial transactions which in fact involved the proceeds of specified unlawful activitYI to wit gambling business in violation of Title 18 Sections 1955 and 1084 1 1 l an illegal United States Code and New York Penal Law Section 225.10 I 1 knowing that such financial transactions were designed in whole - 18 - and in part to conceal and disguise the nature, location, source, ownership and control of the proceeds of such specified unlawful activity, in violation of Title 18, united states Code, Section 1956 (a) (1) (B) (i) c. It was further a part and an object of the conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, and others known and unknown, willfully and knowingly would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer a monetary instrument and funds from a place in the United states to and through a place outside the United states and to a place in the United states from and through a place outside the united States with the intent to promote the carrying on of a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, united States Code, Sections 1955 and 1084, and New York Penal Law 225.10, all in violation of Title 18, United States Code, Section 1956 (a) (2) (A) . d. It was further a part and an object of the conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, and others known and unknown, willfully and knowingly would and did transport, - 19 - transmit, and transfer, and attempt to transport, transmit, and transfer monetary instruments and funds from a place in the United states to and through a place outside the United States and to a place in the united States from and through a place outside the United States knowing that the monetary instruments and funds involved in the transportations, transmissions, and transfers represented the proceeds of some form of unlawful activity and knowing that such transportations, transmissions, and transfers were designed in whole and in part to conceal and disguise the nature, the location, the source, the ownership, and the control of the proceeds of a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, all in violation of Title 18, United States Code, Section 1956(a) (2) (B) (i). e. It was further a part and an object of the conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, and others known and unknown, in an offense involving and affecting interstate and foreign commerce, would and did knowingly engage in and attempt to engage in monetary transactions, as that term is defined in Title 18, United States Code, Section 1957(f) (1), in criminally derived property that was of a value greater than $10,000, to - 20 - wit, wire transfers in excess of $10,000 between bank accounts in Cyprus controlled by the defendants and bank accounts in the United states controlled by the defendants, such property having been derived from a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, all in violation of Title 18, United States Code, section 1957. Racketeering Act six: Interstate and Foreign Travel or Transportation in Aid of Racketeering Enterprise 23. In or about January 2010, in the Southern District of New York and elsewhere, VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, knowingly and willfully travelled in interstate and foreign commerce and used the mail and a facility in interstate and foreign commerce with intent to distribute the proceeds of an unlawful activity, that is a business enterprise involving gambling in violation of Title 18 United states Code Sections 1955 and 1084, and New York Penal Law Section 225.10, and did distribute the proceeds of that unlawful activity, to wit, TRINCHER and GOLUBCHIK caused $3,000,000 in proceeds from their illegal gambling business to be sent from a bank account they controlled in Cyprus to a bank account they controlled in the - 21 - United states, in violation of Title lS, United States Code, Section 1952 (a) (1) . Racketeering Act Seven: Interstate and Foreign Travel and Transportation in Aid of Racketeering Enterprise 24. In or about September 2012, in the Southern District of New York and elsewhere, VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, knowingly and willfully travelled in interstate and foreign commerce and used the mail and a facility in interstate and foreign commerce with intent to distribute the proceeds of an unlawful activity, that is a business enterprise involving gambling in violation of Title lS United States Code Sections 1955 and 1084, and New York Penal Law Section 225.10, and did distribute the proceeds of that unlawful activity, to wit, TRINCHER and GOLUBCHIK caused approximately $2,200,000 in proceeds from their illegal gambling business to be sent from a bank account they controlled in Cyprus to a bank account they controlled in the United States, in violation of Title lS, United States Code, Section 1952(a) (1). (Title1S, United States Code, Section 1962(c).) - 22 - COUNT THREE (Racketeering Conspiracy: Nahrnad-Trincher Organization) The Grand Jury further charges: The Enterprise 25. At all times relevant to this Indictment, ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD MCCALMONT, the defendants, and others known and unknown, were members and associates of the "Nahmad-Trincher Organization." The Nahmad-Trincher Organization was a criminal organization whose members and associates engaged in crimes, including conducting an illegal gambling business, money laundering, and extortion. 26. The Nahmad-Trincher Organization, including its leadership, membership, and associates, constituted an "enterprise," as that term is defined in Title 18, United States Code, Section 1961(4) -- that is, a group of individuals associated in fact. This enterprise was engaged in, and its activities affected, interstate and foreign commerce. The Nahmad-Trincher Organization was an organized crime group with leadership based in New York City and Los Angeles, and that operated throughout the United States, including in the Southern District of New York, and internationally. The Nahmad-Trincher Organization constituted an ongoing organization whose members - 23 - functioned as a continuing unit for a common purpose of achieving the objectives of the enterprise. 27. The criminal conduct of the Nahmad-Trincher Organization was directed principally, though not exclusively, by its leaders: ILLYA TRINCHER, son of VADIM TRINCHER, a/k/a "Dima," HILLEL NAHMAD, a/k/a "Helly," and NOAH SIEGEL, a/k/a "The Oracle," the defendants, who were based in New York City. ILLYA TRINCHER, NAHMAD, and SIEGEL worked together to lead multiple related criminal ventures including an illegal gambling business, money laundering, and other crimes. TRINCHER, NAHMAD, and SIEGEL were assisted by numerous criminal partners and associates throughout the United States, Europe, and elsewhere. 28. The Nahmad-Trincher Organization was a high- stakes illegal gambling business run out of New York City and Los Angeles that catered primarily to multi-millionaire and billionaire clients. The Nahmad-Trincher Organization used online gambling websites, operating illegally in the United States, to operate an illegal gambling business that generated tens of millions of dollars in bets each year. 29. The Nahmad-Trincher Organization laundered the proceeds of the gambling operation through a host of American bank accounts and Titan P & H LLC ("Titan"), a plumbing company in the Bronx that the Nahmad-Trincher Organization acquired a fifty percent interest in as repayment of a gambling debt. - 24 - 30. The Nahmad-Trincher Organization was financed by a number of different individuals and entities, including the Helly Nahmad Gallery in New York City, an art gallery operated by HILLEL NAHMAD, a/k/a "Helly," the defendant, in the Carlyle Hotel in New York City; NAHMAD's father, a billionaire art dealer located in Europe; and JH Capital Inc., an investment firm run by JOHN HANSON, the defendant. The Defendants 31. ILLYA TRINCHER, the defendant, was a participant in the enterprise, the Nahmad-Trincher Organization, and was a leader of the enterprise. In that capacity, TRINCHER participated in and profited from various crimes, which he committed along with other members and associates of the NahmadTrincher Organization. Among other things, TRINCHER oversaw a high-stakes illegal gambling business. 32. HILLEL NAHMAD, a/k/a "Helly," the defendant, was a participant in the enterprise, the Nahmad-Trincher Organization, and was a leader of the enterprise. In that capacity, NAHMAD participated in and profited from various crimes, which he committed along with other members and associates of the Nahmad-Trincher Organization. Among other things, NAMHAD worked with TRINCHER to launder tens of millions of dollars on behalf of the illegal gambling business. - 25 - 33. NOAH SIEGEL, a/k/a "The Oracle," the defendant, was a participant in the enterprise, the Nahmad-Trincher Organization, and was a leader of the enterprise. In that capacity, SIEGEL participated in and profited from various crimes, which he committed along with other members and associates of the Nahmad-Trincher Organization. Among other things, SIEGEL worked with TRINCHER to oversee a high-stakes illegal gambling business. 34. JOHN HANSON, ARTHUR AZEN, JOHN HIRSCH, and DON MCCALMONT, the defendants, were also participants in the enterprise, the Nahmad-Trincher Organization. In this capacity, these defendants participated in and profited from various crimes, including operating an illegal gambling business and money laundering, which they committed along with other members and associates of the Nahmad-Trincher Organization. Purposes of the Enterprise 35. The purposes of the enterprise included the following: a. enriching the leaders, members, and associates of the enterprise through an illegal gambling business, money laundering, extortion, and other crimes; and b. avoiding detection of their illegal conduct in order to continue to enrich themselves. - 26 - Means and Methods of the Enterprise 36. Among the means and methods by which ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD MCCALMONT, the defendants, and their co-conspirators, and other members and associates conducted and participated in the conduct of the affairs of the Nahmad-Trincher Organization were the following: a. Members and associates of the Nahmad- Trincher Organization and their co-conspirators worked together on a range of criminal money-making schemes, including operating an illegal international gambling business that catered to multi-millionaires and billionaires. b. Members and associates of the Nahmad- Trincher Organization and their co-conspirators employed a sophisticated money laundering scheme to launder tens of millions of dollars through various bank accounts and corporations, including Titan. The Racketeering Conspiracy 37. From at least in or about 2006, up to and including on or about the date of this Indictment, ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD MCCALMONT, the defendants, and others known and unknown, in the - 27 - Southern District of New York and elsewhere, being persons employed by and associated with the racketeering enterprise described in paragraphs 25 through 34 above, namely, the NahmadTrincher Organization, which enterprise was engaged in, and the activities of which affected, interstate and foreign commerce, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to violate Title 18, United States Code, section 1962(c), to wit, to conduct and participate, directly and indirectly, in the conduct of such enterprise's affairs through the collection of unlawful debt as set forth in paragraph 38 below, and through a pattern of racketeering activity as set forth below in paragraph 39. Collection of Unlawful Debt 38. The collection of unlawful debt, as that term is defined in Title 18, United States Coder Section 1961(6) r through which the defendants and their co-conspirators agreed to conduct and participate directly and indirectly in the conduct of the affairs of the enterpriser consisted of the collection of unlawful gambling debts r that iS r debts incurred and contracted in gambling activity which was in violation of the law of the United States and the law of the State of New York and which was incurred in connection with a business of gambling in violation of the law of the United States and the law of the State of New York. It was a part of the conspiracy that each defendant - 28 - agreed that a conspirator would commit at least one collection of unlawful debt in the conduct of the affairs of the enterprise. The Pattern of Racketeering 39. The pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD MCCALMONT, the defendants, and .their coconspirators agreed to conduct and participate in the conduct of the affairs of the enterprise consisted of multiple acts indictable under the following federal and state statutes: a. Title 18, United States Code, Section 1955 (operation of an illegal gambling business) b. Title 18, United States Code, Sections 1956 and 1957 (money laundering) c. i Title 18, United States Code, section 1084 (transmission of wagering information) d. i i Title 18, United States Code, Section 1952 (interstate and foreign travel and transportation in aid of racketeering enterprises) e. i Title 18, United States Code, Section 894 (collection of extensions of credit by extortionate means) - 29 - i and f. multiple acts involving gambling, in violation of New York Penal Law Section 225.10. It was further a part of the conspiracy that the defendants agreed that a conspirator would commit at least two acts of racketeering activity in the conduct of the affairs of the enterprise. (Title 18, United States Code, Section 1962(d).) COUNT FOUR (Racketeering: Nahmad-Trincher Organization) The Grand Jury further charges: 40. The allegations contained in paragraphs 25 through 39 above are hereby repeated, realleged, and incorporated by reference herein as though fully set forth at length for the purpose of alleging Count Four of this Indictment. 41. From at least in or about 2006, up to and including on or about the date of this Indictment ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," ARTHUR AZEN, DON MCCALMONT and JOHN HANSON, the defendants, and others known and unknown, in the Southern District of New York and elsewhere, being persons employed by and associated with the racketeering enterprise described in paragraphs 25 through 39 above, namely, the Nahmad-Trincher - 30 - Organization, which enterprise was engaged in, and the activities of which affected, interstate and foreign commerce, willfully and knowingly did conduct and participate, directly and indirectly, in the conduct of such enterprise's affairs through a pattern of racketeering activity, as described in paragraphs 42 through 49, and the collection of unlawful debt, as described in paragraph 50. The Pattern of Racketeering 42. The pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), consisted of the following acts: Racketeering Act One: 43. Illegal Gambling Business ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, operated an illegal international gambling business that catered primarily to celebrities, professional poker players, and very wealthy individuals working in the financial industry. The defendants committed the following acts, any of which alone constitutes the commission of Racketeering Act One: a. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, knowingly and willfully did - 31 - conduct, finance, manage, supervise, direct, and own all and part of an illegal gambling business, as that term is defined in Title 18, United States Code, Section 1955 (b) (1), (2), and (3), to wit, the defendants operated a bookmaking business which violated New York Penal Law 225.10, involved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part of such business, and had been and remained in substantially continuous operation for a period in excess of thirty days and had a gross revenue of $2,000 in any single day, in violation of Title 18 United States Code, Section 1955 (a) . b. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, knowingly and willfully did advance and profit from unlawful gambling activity by engaging in bookmaking to the extent that they received and accepted in anyone day more than five bets totaling more than $5,000, in violation of New York Penal Law Section 225.10. c. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," - 32 - and JOHN HANSON, the defendants, knowingly and willfully being engaged in the business of betting and wagering, did use a wire communication facility for the transmission in interstate and foreign commerce of bets and wagers and information assisting in the placing of bets and wagers on sporting events and contests, and for the transmission of wire communications which entitled the recipient to receive money and credit as a result of bets and wagers, and for information assisting in the placing of bets and wagers, in violation of Title 18, United States Code, Section 1084. Racketeering Act Two: 44. Extortion of Client-3 From at least in or about 2010, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ILLYA TRINCHER, DON MCCALMONT, ARTHUR AZEN, and JOHN HANSON, the defendants, and others known and unknown, willfully and knowingly did participate in the use of extortionate means, as that term is defined in Title 18, United States Code, Section 891(7), to collect and attempt to collect extensions of credit, as that term is defined in Title 18, United States Code, Section 891(1), and to punish a person, to wit, thereof, "Client-3," for the nonrepayment in violation of Title 18, United States Code, Section 894 (a) (1) and (2). - 33 - Racketeering Act Three: 45. Money Laundering Conspiracy ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," DON MCCALMONT, ARTHUR AZEN, and JOHN HANSON, the defendants, participated in an international conspiracy to launder tens of millions of dollars in proceeds from their illegal gambling business. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to violate Sections 1956 (a) (1) (A) (i), (a) (1) (A) (ii), (a) (1) (B) (i), (a) (2) (A), and (a) (2) (B) (i), and 1957 of Title 18, United States Code. a. It was a part and an object of the conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, and others known and unknown, knowing that the property involved in financial transactions represented the proceeds of some form of unlawful activity, willfully and knowingly would and did conduct and attempt to conduct financial transactions which in fact involved the proceeds of specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United - 34 - states Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, knowing that such financial transactions were conducted with the intent to promote the carrying on of specified unlawful activity, to wit, an illegal gambling business, in violation of Title 18, United States Code, Section 1956 (a) (1) (A) (i) . b. It was further a part and an object of the conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a liThe Oracle," ARTHUR AZEN, DON MCCALMONT, and JOHN HANSON, the defendants, and others known and unknown, knowing that the property involved in financial transactions represented the proceeds of some form of unlawful activity, willfully and knowingly would and did conduct and attempt to conduct financial transactions which in fact involved the proceeds of specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, knowing that such financial transactions were conducted with the intent to engage in conduct constituting a violation of sections 7201 and 7206 of the Internal Revenue Code of 1986, in violation of Title 18, United States Code, Section 1956(a) (1) (A) (ii). c. It was further a part and an object of the conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," ARTHUR AZEN, DON MCCALMONT, and - 35 - JOHN HANSON, the defendants, and others known and unknown, knowing that the property involved in financial transactions represented the proceeds of some form of unlawful activity willfully and knowingly would and did conduct and attempt to conduct financial transactions which in fact involved the proceeds of specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, knowing that such financial transactions were designed in whole and in part to conceal and disguise the nature, location, source, ownership and control of the proceeds of specified unlawful activity, in violation of Title 18, United States Code, Section 1956(a) (1) (B) (i) d. It was further a part and an object of the conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, and others known and unknown, willfully and knowingly would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States and to a place in the United States from and through a place outside the United States with the intent to promote the carrying on of a specified unlawful activity, to wit, an illegal gambling business in - 36 - violation of Title 18, united States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, all in violation of Title 18, United States Code, Section 1956(a) (2) (A). e. It was further a part and an object of the conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, and others known and unknown, in an offense involving and affecting interstate and foreign commerce, would and did engage in and attempt to engage in monetary transactions, as that term is defined in Title 18, United States Code, Section 1957(f) (1), in criminally derived property that was of a value greater than $10,000, to wit, wire transfers in excess of $10,000 between various bank accounts controlled by the defendants and clients of the illegal gambling business, such property having been derived from a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, all in violation of Title 18, United States Code, Section 1957. Racketeering Act Four: Interstate and Foreign Travel and Transportation in Aid of Racketeering Enterprise 46. On or about September 12, 2012, in the Southern District of New York and elsewhere, HILLEL NAHMAD, a/k/a "Helly Nahmad," the defendant, knowingly and willfully travelled in - 37 - interstate and foreign commerce and used the mail and a facility in interstate and foreign commerce with intent to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, that is a business enterprise involving gambling in violation of Title 18 united states Code Sections 1955 and 1084, and New York Penal Law Section 225.10, and did promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on of an unlawful activity, to wit, NAHMAD caused $500,000 to be sent from his father's bank account in Switzerland to ILLYA TRINCHER, the defendant, in the united States, in violation of Title 18, united States Code, Section 1952(a) (1). Racketeering Act Five: Interstate and Foreign Travel and Transportation in Aid of Racketeering Enterprise 47. On or about September 12, 2012, in the Southern District of New York and elsewhere, ILLYA TRINCHER, the defendant, knowingly and willfully travelled in interstate and foreign commerce and used the mail and a facility in interstate and foreign commerce with intent to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, that is a business enterprise involving gambling in violation of Title 18 United States Code Sections 1955 and 1084, and New York Penal - 38 - Law Section 225.10 r and did promoter manager establish r carry on r and facilitate the promotion r management r establishment r and carrying on of an unlawful activitYr to witr TRINCHER caused four hundred r $99 r 800 to be sent from his bank account in New York to an account in Taiwan that was controlled by an online gambling website operating illegally in the United States r in violation of Title 18 r United States Coder Section 1952(a) (1) Racketeering Act Six: Interstate and Foreign Travel and Transportation in Aid of Racketeering Enterprise 48. On or about June 4 r 2011 r in the Southern District of New York and elsewhere r HILLEL NAHMAD r a/k/a "Helly Nahmad r lf the defendantr knowingly and willfully travelled in interstate and foreign commerce and used the mail and a facility in interstate and foreign commerce with intent to otherwise promoter manager establish r carry on r and facilitate the promotion r management r establishment r and carrying on r of an unlawful activitYr that is a business enterprise involving gambling in violation of Title 18 United States Code Sections 1955 and 1084 r and New York Penal Law Section 225.10 r and did promoter manager establish r carry on r and facilitate the promotion r management r establishment r and carrying on of an unlawful activitYr to witr NAHMAD caused $850 r OOO to be sent from his fatherrs bank account in Switzerland to a bank account under the control of NOAH SIEGEL r a/k/a "the Oracle r - 39 - lf in the United states, in violation of Title 18, United states Code, section 1952 (a) (1) Racketeering Act Seven: Transmission of Wagering Information 49. ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, were in the business of illegally betting on professional sporting events and placed millions of dollars of bets through online gambling websites operating illegally in the United States. From at least in or about 2008, up to and including on or about the date of this indictment, in the Southern District of New York and elsewhere, ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the defendants, knowingly and willfully being engaged in the business of betting and wagering, did use a wire communication facility for the transmission in interstate and foreign commerce of bets and wagers and information assisting in the placing of bets and wagers on sporting events and contests, and for the transmission of wire communications which entitled the recipient to receive money and credit as a result of bets and wagers, and for information assisting in the placing of bets and wagers, in violation of Title 18, United States Code, Section 1084. - 40 - Collection of Unlawful Debt 50. The collection of unlawful debt defined by Title 18, United States Code, Section 1961(6), that is, a debt (A) incurred and contracted in gambling activity which was in violation of a law of the United States of America and a law of the State of New York, and (B) which was incurred in connection with the business of gambling in violation of a law of the United States of America, New York State, and a political subdivision thereof, through which ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, and DONALD MCCALMONT, the defendants, did conduct and participate in the affairs of the enterprise, which was engaged in and the activities of which affected interstate commerce, consisted of collecting and attempting to collect an unlawful debt as follows: a. From at least in or about 2010, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," ARTHUR AZEN, DON MCCALMONT, and JOHN HANSON, the defendants, participated in the collection and attempted collection of more than $2,000,000 of unlawful gambling debts from Client-3 by, among other things, acquiring a fifty percent interest in Client-3's plumbing company, Titan. - 41 - (Title 18, United States Code, Section 1962(c).) COUNT FIVE (Illegal Sports Gambling Business: Taiwanchik-Trincher Organization) The Grand Jury further charges: 51. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, knowingly and willfully did conduct, finance, manage, supervise, direct, and own all and part of an illegal gambling business, as that term is defined in Title 18, United States Code, Section 1955 (b) (1), (2), and (3), to wit, the defendants operated a bookmaking business that violated New York Penal Law Section 225.10, involved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part of such business, and had been and remained in substantially continuous operation for a period in excess of thirty days and had a gross revenue of $2,000 in any single day. (Title 18, United States Code, Sections 1955 and 2.) - 42 - COUNT SIX (Acceptance of Financial Instrument for Unlawful Internet Gambling: Taiwanchik-Trincher Organization) The Grand Jury further charges: 52. From at least in or about 2007, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, the defendants, who were engaged in the business of betting and wagering, knowingly and willfully did accept, in connection with the participation of another person in unlawful Internet gambling, credit, and the proceeds of credit, extended to and on behalf of such other person (including credit extended through the use of a credit card); an electronic fund transfer, and funds transmitted by and through a money transmitting business, and the proceeds of an electronic fund transfer and money transmitting service, from and on behalf of such other person; a check, draft, and similar instrument which was drawn by and on behalf of such other person and was drawn on and payable at and through a financial institution; and the proceeds of another form of financial transaction, as the Secretary and the Board of Governors of the Federal Reserve System may jointly prescribe by regulation, which involves a financial institution as a payor and financial intermediary on - 43 - behalf of and for the benefit of such other person, to wit, TOKHTAKHOUNOV, TRINCHER, and GOLUBCHIK operated an illegal bookmaking business that utilized gambling websites operating illegally in the United States. (Title 31, United states Code, Sections 5363 and 5366; Title 18, united States Code, Section 2.) COUNT SEVEN (Money Laundering Conspiracy: Taiwanchik-Trincher Organization) The Grand Jury further charges: 53. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to violate Title 18, United States Code, Sections 1956 (a) (1) (B) (i), (a) (2) (A), and (a) (2) (B) (i), and 1957, to wit, the defendants laundered more than $50,000,000 in sports gambling proceeds through shell companies in Cyprus and the United States of America. 54. It was a part and an object of the conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," - 44 - VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," the defendants, and others known and unknown, knowing that the property involved in financial transactions represented the proceeds of some form of unlawful activity willfully and knowingly would and did conduct and attempt to conduct financial transactions which in fact involved the proceeds of specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, united states Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, knowing that such financial transactions were designed in whole and in part to conceal and disguise the nature, location, source, ownership and control of the proceeds of specified unlawful activity, in violation of Title 18, united States Code, Section 1956(a) (1) (B) (i). 55. It was further a part and an object of the conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," the defendants, and others known and unknown, willfully and knowingly would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer a monetary instrument and funds from a place in the united States to and through a place outside the united States and to a place in the united States from and through a place outside the United States - 45 - with the intent to promote the carrying on of a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United states Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, all in violation of Title 18, United States Code, Section 1956 (a) (2) (A) . 56. It was further a part and an object of the conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," the defendants, and others known and unknown, willfully and knowingly would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer monetary instruments and funds from a place in the United States to and through a place outside the United States and to a place in the United States from and through a place outside the United States knowing that the monetary instruments and funds involved in the transportations, transmissions, and transfers represented the proceeds of some form of unlawful activity and knowing that such transportations, transmissions, and transfers were designed in whole and in part to conceal and disguise the nature, the location, the source, the ownership, and the control of the proceeds of a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, - 46 - all in violation of Title 18, United States Code, Section 1956 (a) (2) (B) (i) . 57. It was further a part and an object of the conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," the defendants, and others known and unknown, in an offense involving and affecting interstate and foreign commerce, would and did engage in and attempt to engage in monetary transactions, as that term is defined in Title 18, United States Code, Section 1957(f) (1), in criminally derived property that was of a value greater than $10,000, to wit, wire transfers in excess of $10,000 between bank accounts in Cyprus controlled by the defendants and bank accounts in the United States controlled by the defendants, such property having been derived from a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, all in violation of Title 18, United States Code, Section 1957. (Title 18, United States Code, Section 1956(h).) COUNT EIGHT (To Collect Extensions of Credit by Extortionate Means) The Grand Jury further charges: - 47 - 58. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, and others known and unknown, knowingly and willfully combined, conspired, confederated, and agreed together and with each other to participate in the use of extortionate means, as that term is defined in Title 18, United states Code, Section 891(7), to collect and attempt to collect extensions of credit, as that term is defined in Title 18, United states Code, Section 891(1), and to punish a person, to wit, gamblers who owed sports gambling debts, for the nonrepayrnent thereof, to wit, TOKHTAKHOUNOV, TRINCHER, and GOLUBCHIK, agreed to use violence and threats of violence to collect sports gambling debts from gamblers. (Title 18, United States Code, Section 894.) COUNT NINE (Illegal Sports Gambling Business: Nahmad-Trincher Organization) The Grand Jury further charges: 59. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, HILLEL NAHMAD, - 48 - a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, JUSTIN SMITH, WILLIAM EDLER, PETER FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a "D.A.," BRYAN ZURIFF, and ABRAHAM MOSSERI, the defendants, knowingly and willfully did conduct, finance, manage, supervise, direct, and own all and part of an illegal gambling business, as that term is defined in Title 18, united States Code, Section 1955 (b) (1), (2), and (3), and aid and abet the same, to wit, NAHMAD, TRINCHER, SIEGEL, HANSON, HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, AARON, ZURIFF, and MOSSERI, operated a bookmaking business that violated New York Penal Law Section 225.10, involved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part of such business, and had been and remained in substantially continuous operation for a period in excess of thirty days and had a gross revenue of $2,000 in any single day. (Title 18, united States Code, Sections 1955 and 2.) COUNT TEN (Transmission of Sports Wagering Information: Nahmad-TrincherOrganization) The Grand Jury further charges: 60. From at least in or about 2008, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," - 49 - JOHN HANSON, and JONATHAN HIRSCH, the defendants, being engaged in the business of betting and wagering, knowingly and willfully did use a wire communication facility for the transmission in interstate and foreign commerce of bets and wagers and information assisting in the placing of bets and wagers on a sporting event and contest, and for the transmission of a wire communication which entitled the recipient to receive money and credit as a result of bets and wagers, and for information assisting in the placing of bets and wagers, and aided and abetted the same, to wit, NAHMAD, TRINCHER, SIEGEL, HANSON, HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, AARON, ZURIFF, and MOSSERI, the defendants transmitted wagering information concerning sporting events via emails sent across state lines. (Title 18, United States Code, Sections 1084 and 2.) COUNT ELEVEN (Acceptance of Financial Instrument for Unlawful Internet Sports Gambling: Trincher-Nahmad Organization) The Grand Jury further charges: 61. From at least in or about 2008, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, a/k/a "Hersch," JUSTIN SMITH, WILLIAM EDLER, PETER FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a - 50 - "D.A. ," BRYAN ZURIFF, and ABRAHAM MOSSERI, the defendants, who were engaged in the business of betting and wagering, knowingly and willfully did accept, in connection with the participation of another person in unlawful Internet gambling, credit, and the proceeds of credit, extended to and on behalf of such other person (including credit extended through the use of a credit card); an electronic fund transfer, and funds transmitted by and through a money transmitting business, and the proceeds of an electronic fund transfer and money transmitting service, from and on behalf of such other person; a check, draft, and similar i ! instrument which was drawn by and on behalf of such other person and was drawn on and payable at and through a financial institution; and the proceeds of another form of financial transaction, as the Secretary and the Board of Governors of the Federal Reserve System may jointly prescribe by regulation, which involved a financial institution as a payor and financial intermediary on behalf of and for the benefit of such other person, and aided and abetted the same, to wit, NAHMAD, TRINCHER, SIEGEL, HANSON, HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, AARON, ZURIFF, and MOSSERI, operated an illegal bookmaking business that utilized gambling websites operating illegally in the United States. (Title 31, United States Code, Sections 5363 and 5366; Title 18, United States Code, Section 2.) - 51 - < COUNT TWELVE (Money Laundering Conspiracy: Nahmad-Trincher Organization) The Grand Jury further charges: 62. From at least in or about 2006, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER SKYLLAS, and RONALD UY, the defendants, and others known and unknown, knowingly and willfully did combine, conspire, confederate, and agree together and with each other to violate Title 18, United States Code, Sections, 1956(a) (1) (A) (i), (a) (1) (A) (ii), (a) (1) (B) (i), (a) (2) (A), and (a) (2) (B) (i), and 1957 of Title 18, United States Code .. 63. It was a part and an object of the conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER SKYLLAS, and RONALD UY, the defendants, and others known and unknown, knowing that the property involved in financial transactions represented the proceeds of some form of unlawful activity, willfully and knowingly would and did conduct and attempt to conduct financial - 52 - transactions which in fact involved the proceeds of specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Sections 225.10, knowing that such financial transactions were conducted with the intent to promote the carrying on of specified unlawful activity, to wit, an illegal gambling business, to wit the defendants laundered more than $50,000,000 in gambling proceeds through various bank accounts and businesses, in violation of Title 18, United States Code, Section 1956 (a) (1) (A) (i) . 64. It was further a part and an object of the conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER SKYLLAS, and RONALD UY, the defendants, and others known and unknown, knowing that the property involved in financial transactions represented the proceeds of some form of unlawful activity, willfully and knowingly would and did conduct and attempt to conduct financial transactions which in fact involved the proceeds of specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, knowing that such financial transactions were conducted with the intent to engage in conduct constituting a violation of section - 53 - 7201 and 7206 of the Internal Revenue Code of 1986, in violation of Title 18, United States Code, Section 1956(a) (1) (A) (ii). 65. It was further a part and an object of the conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER SKYLLAS, and RONALD UY, the defendants, and others known and unknown, knowing that the property involved in such financial transactions represented the proceeds of some form of unlawful activity, willfully and knowingly would and did conduct and attempt to conduct financial transactions which in fact involved the proceeds of specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, knowing that such financial transactions were designed in whole and in part to conceal and disguise the nature, location, source, ownership and control of the proceeds of specified unlawful activity, in violation of Title 18, United States Code, Section 1956 (a) (1) (B) (i) . 66. It was further a part and an object of the conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, and RONALD UY, the defendants, and others known and unknown, willfully and knowingly would and did transport, transmit, and transfer, and - 54 - attempt to transport, transmit, and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States and to a place in the United States from and through a place outside the United States with the intent to promote the carrying on of a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, all in violation of Title 18, united States Code, Section 1956 (a) (2) (A). 67. It was further a part and an object of the conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER SKYLLAS, and RONALD UY, the defendants, and others known and unknown, in an offense involving and affecting interstate and foreign commerce, would and did engage in and attempt to engage in monetary transactions, as that term is defined in Title 18, United States Code, Section 1957(f) (1), in criminally derived property that was of a value greater than $10,000, to wit, wire transfers in excess of $10,000 between various bank accounts controlled by the defendants and clients of the illegal gambling business, such property having been derived from a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and - 55 - 1084 r and New York Penal Law Section 225.10 r all in violation of Title 18 r United States Coder Section 1957. (Title 18 r United States Coder Section 1956(h). COUNT THIRTEEN (Structuring) The Grand Jury further charges: 68. From at least in or about January 2012 r up to and including on or about the date of this Indictment r in the Southern District of New York and elsewhere r RONALD UY and ILLYA TRINCHER r the defendants r knowingly and willfullYr and for the purpose of evading the reporting requirements of Section 5313(a) of Title 31r united States Coder and the regulations promulgated thereunder r did structure and assist in structuring r and attempted to structure and assist in structuring r a transaction with one and more domestic financial institutions r and did aid and abet the samer to witr RONALD UY r a branch manager at a JPMorgan Chase Bank located in New York City (the "Bank") r did assist TRINCHER in structuring several transactions at the Bank designed in part to avoid generating currency transaction reports. (Title 31r United States Coder Sections 5324 (a) (3) and (d) (1) Title 18 r United Stated Coder Section 2.) - 56 - COUNT FOURTEEN (Extortion of Client-3) The Grand Jury further charges: 69. From at least in or about January 2010, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ILLYA TRINCHER, ARTHUR AZEN, DON MCCALMONT, and JOHN HANSON, the defendants, willfully and knowingly did participate in the use of extortionate means, as that term is defined ln Title 18, United States Code, Section 891(7), to collect and attempt to collect extensions of credit, as that term is defined in Title 18, United States Code, Section 891(1), and to punish a person, to wit, Client-3, for the nonrepayment thereof, to wit, TRINCHER, AZEN, MCCALMONT, and HANSON threatened to cause, and did cause, harm to Titan, Client-3's plumbing company, to collect and attempt to collect a $2,000,000 gambling debt that Client-3 owed to the Trincher-Nahmad Organization. (Title 18, United States Code, Sections 894(a) (1) and (a) (2).) COUNT FIFTEEN (Wire Fraud Conspiracy) The Grand Jury further charges: 70. From at least in or about March 2012, up to and including on or about the date of this indictment, in the Southern District of New York and elsewhere, HILLEL NAHMAD, - 57 - a/k/a "Helly," and NICHOLAS HIRSH, the defendants, and others known and unknown, knowingly and willfully did combine, conspire, confederate, and agree together and with each other to violate Title 18, United States Code, Section 1343. 71. It was a part and an object of the conspiracy that HILLEL NAHMAD, a/k/a "Helly," and NICHOLAS HIRSH, the defendants, and others known and unknown, having devised and intending to devise any scheme and artifice to defraud, and for obtaining money and property by means of false and fraudulent pretenses, representations, and promises, would and did transmit and cause to be transmitted by means of wire, radio, and television communication in interstate and foreign commerce, a writing, sign, signal, picture, and sound for the purpose of executing such scheme and artifice, in violation of Title 18, united States Code, Section 1343, to wit, HILLEL NAHMAD, a/k/a "Helly," and NICHOLAS HIRSCH used interstate and international wires in furtherance of a scheme to defraud an individual concerning a sale of a piece of art that they claimed to be worth approximately $300,000 but was in fact worth at least approximately $50,000 less. (Title 18, united States Code, Section 1349.) - 58 - COUNT SIXTEEN (Illegal Sports Gambling Business: Druzhinsky organization) The Grand Jury further charges: 72. From at least in or about 2008~ up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, DMITRY DRUZHINSKY, ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a "Murashka," and ARTHUR AZEN, the defendants, knowingly and willfully did conduct, finance, manage, supervise, direct, and own all and part of an illegal gambling business, as that term is defined in Title 18, United States Code, Section 1955 (b) (1), (2), and (3), to wit, DRUZHINSKY, ZAVERUKHA, KATCHALOFF, and AZEN operated a bookmaking business that violated New York Penal Law Section 225.10, involved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part of such business, and had been and remained in substantially continuous operation for a period in excess of thirty days and had a gross revenue of $2,000 in any single day. (Title 18, United States Code, Sections 1955 and 2.) - 59 - COUNT SEVENTEEN (Acceptance of Financial Instrument for Unlawful Internet Sports Gambling) The Grand Jury further charges: 73. From at least in or about 2008, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, DMITRY DRUZHINSKY, ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a "Murashka," and ARTHUR AZEN, the defendants, who were engaged in the business of betting and wagering, knowinglY and willfully did accept, in connection with the participation of another person in unlawful Internet gambling, credit, and the proceeds of credit, extended to and on behalf of such other person (including credit extended through the use of a credit card); an electronic fund transfer, and funds transmitted by and through a money transmitting business, and the proceeds of an electronic fund transfer and money transmitting service, from and on behalf of such other person; a check, draft, and similar instrument which was drawn by and on behalf of such other person and was drawn on and payable at and through a financial institution; and the proceeds of another form of financial transaction, as the Secretary and the Board of Governors of the Federal Reserve System have prescribed by regulation, which involves a financial institution as a payor and financial intermediary on behalf of - 60 - and for the benefit of such other person, to wit, DRUZHINSKY, ZAVERUKHA, KATCHALOFF and AZEN, operated an illegal bookmaking business that utilized gambling websites operating illegally in the united States. (Title 31, United states Code, Sections 5363 and 5366; Title 18, united States Code, Section 2.) COUNT EIGHTEEN (Money Laundering Conspiracy) The Grand Jury further charges: 74. From at least in or about 2008, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, DMITRY DRUZHINKSKY, ANATOLY GOLUBCHIK, a/k/a "Tony," ILYA ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to violate Sections 1956 (a) (1) (B) (i), (a) (2) (A) , and (a) (2) (B) (i), and 1957 of Title 18, United States Code, to wit, dollars in p~oceeds the defendants laundered millions of from DRUZHINSKY's sports gambling business through various companies including a real estate company in New York, New York, a car repair shop in Brooklyn, New York, and a company that sells used cars over the internet. 75. It was a part and an object of the conspiracy that DMITRY DRUZHINKSKY, ANATOLY GOLUBCHIK, a/k/a "Tony," ILYA - 61 - ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, and others known and unknown, knowing that the property involved in such financial transactions represented the proceeds of some form of unlawful activity, willfully and knowingly would and did conduct and attempt to conduct financial transactions which in fact involved the proceeds of specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, united States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, knowing that such financial transactions were designed in whole and in part to conceal and disguise the nature, location, source, ownership and control of the proceeds of specified unlawful activity, in violation of Title 18, united States Code, Section 1956 (a) (1) (B) (i) . 76. It was further a part and an object of the conspiracy that DMITRY DRUZHINKSKY, ANATOLY GOLUBCHIK, a/k/a "Tony," ILYA ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, and others known and unknown, willfully and knowingly would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States and to a place in the United States from and through a place outside the United States with the intent to promote the carrying on of a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, - 62 - united States Code/ Sections 1955 and 1084/ and New York Penal Law Section 225.10/ all in violation of Title 18/ United States Code/ Section 1956 (a) (2) (A) . 77. It was further a part and an object of the conspiracy that DMITRY DRUZHINKSKY/ ANATOLY GOLUBCHIK/ a/k/a "Tony/II ILYA ROZENFELD/ and ANATOLY SHTEYNGRAB/ the defendants/ and others known and unknown/ willfully and knowingly would and did transport/ transmit/ and transfer/ and attempt to transport/ transmit/ and transfer monetary instruments and funds from a place in the united States to and through a place outside the United States and to a place in the United States from and through a place outside the United States knowing that the monetary instruments and funds involved in the transportations/ transmissions/ and transfers represented the proceeds of some form of unlawful activity and knowing that such transportations/ transmissions/ and transfers were designed in whole and in part to conceal and disguise the nature/ the location/ the source/ the ownership/ and the control of the proceeds of a specified unlawful activity/ to wit/ an illegal gambling business in violation of Title 18/ United States Code/ Sections 1955 and 1084/ and New York Penal Law Section 225.10/ all in violation of Title 18/ United States Code/ Section 1956 (a) (2) (B) (i) . 78. It was further a part and an object of the conspiracy that DMITRY DRUZHINKSKY/ ANATOLY GOLUBCHIK/ a/k/a - 63 - "Tony," ILYA ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, and others known and unknown, in an offense involving and affecting interstate and foreign commerce, would and did engage in and attempt to engage in monetary transactions, as that term is defined in Title 18, United States Code, Section 1957(f) (1), in criminally derived property that was of a value greater than $10,000, to wit, wire transfers in excess of $10,000 between bank accounts in Cyprus controlled by the defendants and bank accounts in the United States controlled by the defendants, such property having been derived from a specified unlawful activity, to wit, an illegal gambling business in violation of Title 18, United States Code, Sections 1955 and 1084, and New York Penal Law Section 225.10, all in violation of Title 18, United States Code, Section 1957. (Title 18, United States Code, Section 1956(h).) COUNT NINETEEN (To Collect Extensions of Credit by Extortionate Means) The Grand Jury further charges: 79. From at least in or about January 2012, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, ARTHUR AZEN, KIRILL RAPOPORT, and MOSHE ORATZ, the defendants, and others known and unknown, knowingly and willfully combined, conspired, - 64 - confederated, and agreed together and with each other to participate in the use of extortionate means, as that term is defined in Title 18, United states Code, Section 891(7), to collect and attempt to collect extensions of credit, as that term is defined in Title 18, United States Code, Section 891(1), and to punish a person, to wit, gamblers who owed poker and/or sports gambling debts, for the nonrepayment thereof, to wit, AZEN, RAPOPORT, and ORATZ, agreed to use violence and threats of violence to collect sports and poker gambling debts from gamblers. (Title 18, united States Code, Section 894.) COUNT TWENTY (Illegal Poker Business) The Grand Jury further charges: 80. From at least in or about 2010, up to and including on or about the date of this Indictment, in the Southern District of New York and elsewhere, EUGENE TRINCHER, EDWIN TING, a/k/a "Eddie," ARTHUR AZEN, JOSEPH MANCUSO, WILLIAM BARBALAT, YUGESHWAR RAJ KUMAR , a/k/a "Mateo Hermatte," MOLLY BLOOM, the defendants, knowingly and willfully did conduct, finance, manage, supervise, direct, and own all and part of an illegal gambling business, as that term is defined in Title 18, United States Code, Section 1955 (b) (1), - 65 - (2), and (3), and did aid and abet the same, to wit, TRINCHER, TING, AZEN, MANCUSO, BARBALAT, RAJKUMAR, and BLOOM, operated an illegal poker business which violated New York Penal Law Section 225.05, involved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part of such business, and had been and remained in substantially continuous operation for a period in excess of thirty days and had a gross revenue of $2,000 in any single day. (Title 18, United States Code, Sections 1955 and 2.) COUNT TWENTY-ONE (Travel Act) The Grand Jury further charges: 81. In or about December 2011, in the Southern District of New York and elsewhere, EUGENE TRINCHER, the defendant, intentionally and knowingly did travel in interstate and foreign commerce and use the mail and a facility in interstate and foreign commerce, with intent to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, and thereafter did distribute and attempt to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate - 66 - the promotion, management, establishment, and carrying on, of an unlawful activity, to wit, TRINCHER caused a check in the amount of $10,000, issued in connection with operating an illegal poker game in New York City, to be deposited into a bank account in Connecticut. (Title 18, United States Code, Sections 1952 and 2.) COUNT TWENTY-TWO (Travel Act) The Grand Jury further charges: 82. In or about November 2011, in the Southern District of New York and elsewhere, EDWIN TING, a/k/a "Eddie," the defendant, intentionally and knowingly did travel in interstate and foreign commerce and use the mail and a facility in interstate and foreign commerce, with intent to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, and thereafter did distribute and attempt to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, to wit, TING, deposited a check in the amount of $250,000 from a bank account in California into a bank - 67 - account in New York, in connection with operating an illegal poker game in New York City. (Title 18, united States Code, Sections 1952 and 2.) COUNT TWENTY-THREE (Travel Act) The Grand Jury further charges: 83. In or about March 2011, in the Southern District of New York and elsewhere, ARTHUR AZEN, the defendant, intentionally and knowingly did travel in interstate and foreign commerce and use the mail and a facility in interstate and foreign commerce, with intent to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, and thereafter did distribute and attempt to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, to wit, AZEN deposited a check from WILLIAM BARBALAT, the defendant, in the amount of $4,000 in a connection with operating an illegal - 68 - poker game in New York City, which check cleared by interstate wire. (Title 18, United States Code, Sections 1952 and 2.) COUNT TWENTY-FOUR (Travel Act) The Grand Jury further charges: 84. In or about February 2012, in the Southern District of New York and elsewhere, JOSEPH MANCUSO, the defendant, intentionally and knowingly did travel in interstate and foreign commerce and use the mail and a facility in interstate and foreign commerce, with intent to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, and thereafter did distribute and attempt to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, to wit, MANCUSO wrote a check in the amount of $30,000 in connection with operating an illegal poker game in New York City, which check was deposited into a bank account in Connecticut. (Title 18, United States Code, Sections 1952 and 2.) - 69 - COUNT TWENTY-FIVE (Travel Act) The Grand Jury further charges: 85. In or about March 2011, in the Southern District of New York and elsewhere, WILLIAM BARBALAT, the defendant, intentionally and knowingly did travel in interstate and foreign commerce and use the mail and a facility in interstate and foreign commerce, with intent to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, and thereafter did distribute and attempt to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, to wit, BARBALAT wrote a check to ARTHUR AZEN, the defendant, in the amount of $4,000 in a connection with operating an illegal poker game in New York City, which check cleared by interstate wire. (Title 18, United States Code, Sections 1952 and 2.) - 70 - COUNT TWENTY-SIX (Travel Act) The Grand Jury further charges: 86. In or about January 2011, in the Southern District of New York and elsewhere, YUGESHWAR RAJ KUMAR , a/k/a "Mateo Hermatte," the defendant, intentionally and knowingly did travel in interstate and foreign commerce and use the mail and a facility in interstate and foreign commerce, with intent to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, and thereafter did distribute and attempt to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carryon, and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, to wit, RAJ KUMAR wrote a check from his New Jersey bank account in the amount of $11,500 in connection with operating an illegal poker game in New York City. (Title 18, United States Code, Sections 1952 and 2.) - 71 - COUNT TWENTY-SEVEN (Travel Act) The Grand Jury further charges: 87. In or about June 2010, in the Southern District of New York and elsewhere, MOLLY BLOOM, the defendant, intentionally and knowingly did travel in interstate and foreign commerce and use the mail and a facility in interstate and foreign commerce, with intent to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carry onl and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, and thereafter did distribute and attempt to distribute the proceeds of an unlawful activity, and to otherwise promote, manage, establish, carry on l and facilitate the promotion, management, establishment, and carrying on, of an unlawful activity, to wit, BLOOM deposited two checks totally $25,900 into a bank account in California in connection with operating an illegal poker game in New York City. (Title 18, United States Code, Sections 1952 and 2.) - 72 - Forfeiture Allegation as to Counts One and Two (Taiwanchik-Trincher Organization) 88. The allegations contained in Counts One and Two of this Indictment are hereby repeated, realleged, and incorporated by reference herein as though fully set forth at length for the purpose of alleging forfeiture pursuant to Title 18, united States Code, Section 2461(c). 89. Pursuant to Rule 32.2(a), Fed. R. Crim. P., ALIMZHAN TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, are hereby notified that, upon conviction of the violation or violations of Title 18, united States Code, Section 1962, in Counts One and Two the Indictment, the defendants shall forfeit, pursuant to Title 18, united States Code, Section 1963: a. all interests acquired and maintained in violation of Title 18, United States Code, Section 1962i b. all interests in, securities of, claims against, and property and contractual rights of any kind affording a source of influence over, the enterprise named and described herein which the defendants established, operated, controlled, conducted, and participated in the conduct of, in violation of Title 18, United States Code, Section 1962i and - 73 - c. all property constituting and derived from proceeds obtained, directly and indirectly, from racketeering activity in violation of Title 18, United States Code, Section 1962. 90. The property subject to forfeiture to the United States pursuant to Title 18, United States Code, Section 1963 (a) (1), (a) (2), and (a) (3), includes, but is not limited at least $50 million which represents the total of the interests acquired and the gross proceeds obtained through the violation of Title 18, united States Code, Section 1962, and the following specific property which constitutes and is derived from proceeds obtained, directly and indirectly, from racketeering activity in violation of Title 18, United States Code, Section 1962: a. 721-725 5th Avenue, Apartment 63A and B, New b. 971 Madison Avenue, Units 8A, Band C, New c. 16001 Collins Avenue, Unit 806, Sunny Isles York, NY 10022; York, NY 10021; Beach, FL 33160; and d. 16001 Collins Avenue, Unit 1206, Sunny Isles Beach, FL 33160. 91. Pursuant to Title 18, United States Code, Section 1963(m), ALIMZHAN TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL - 74 - SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, shall forfeit substitute property up to the value of the property described in the previous paragraph if that property, as a result of any act or omission of the defendants: a. cannot be located upon the exercise of due b. has been transferred or sold to, or diligence; deposited with, a third party; c. has been placed beyond the jurisdiction of d. has been substantially diminished in value; e. has been commingled with other property this Court; and which cannot be divided without difficulty. 92. The above-named defendants are jointly and severally liable for the forfeiture allegations alleged above. (Title 18, united States Code, section 1963.) Forfeiture Allegation as to Counts Three and Four (Nahmad-Trincher Organization) 93. The allegations contained in Counts Three and Four of this Indictment are hereby repeated, realleged, and incorporated by reference herein as though fully set forth at - 75 - length for the purpose of alleging forfeiture pursuant to Title 18, United States Code, Section 2461(c). 94. Pursuant to Rule 32.2(a), Fed. R. Crim. P., ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD MCCALMONT, the defendants, are hereby notified that, upon conviction of the violation or violations of Title 18, United States Code, Section 1962, as charged in Counts Three and Four of this Indictment, the defendants shall forfeit, pursuant to Title 18, United States Code, Section 1963: a. all interests acquired and maintained in violation of Title 18, United States Code, Section 1962; b. all interests in, securities of, claims against, and property and contractual rights of any kind affording a source of influence over, the enterprise named and described herein which the defendants established, operated, controlled, conducted, and participated in the conduct of, in violation of Title 18, United States Code, Section 1962; and c. all property constituting and derived from proceeds obtained, directly and indirectly, from racketeering activity in violation of Title 18, United States Code, Section 1962. 95. The property subject to forfeiture to the United States pursuant to Title 18, United States Code, Section - 76 - 1963 (a) (1) I (a) (2) I and (a) (3) I includes I but is not limited at least $50 million which represents the total of the interests acquired and the gross proceeds obtained through the violation of Title 18 1 united States Codel Section 1962 and is derived from proceeds obtained I 1 which constitutes directly and indirectlYI from racketeering activity in violation of Title 18 States Code I 1 United Section 1962. 96. Pursuant to Title 18 1 United States Codel Section 1963(m) I ILLYA TRINCHER I HILLEL NAHMADI a/k/a "Hellylll NOAH SIEGEL I a/k/a "The Oracle l ll JOHN HANSON I JONATHAN HIRSCHI ARTHUR AZEN I and DONALD MCCALMONT I the defendants I shall forfeit substitute property up to the value of the property described in the previous paragraph if that property I as a result of any act or omission of the defendants: a. cannot be located upon the exercise of due b. has been transferred or sold diligence; deposited with l tOI or a third party; c. has been placed beyond the jurisdiction of d. has been substantially diminished in value; e. has been commingled with other property this Court; and which cannot be divided without difficulty. - 77 - 97. The above-named defendants are jointly and severally liable for the forfeiture allegations alleged above. (Title 18, United States Code, Section 1963.) Forfeiture Allegation as to Counts Five, Eight, Nine, Ten, Fourteen, Fifteen, Sixteen, and Nineteen to Twenty-Seven 98. As a result of committing the illegal gambling business, extortion, transmission of sports wagering information, travel act, and wire fraud offenses alleged in Counts Five, Eight, Nine, Ten, Fourteen, Fifteen, Sixteen, and Nineteen to Twenty-Seven of this Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, JUSTIN SMITH, WILLIAM EDLER, PETER FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a "D.A.," BRYAN ZURIFF, ABRAHAM MOSSERI, DMITRY DRUZHINSKY, ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a "Murashka," ARTHUR AZEN, KIRILL RAPOPORT, MOSHE ORATZ, EUGENE TRINCHER, EDWIN TING, a/k/a "Eddie," JOSEPH MANCUSO, WILLIAM BARBALAT, YUGESHWAR RAJKUMAR, a/k/a "Mateo Hermatte," MOLLY BLOOM, the defendants, shall forfeit to the United States pursuant to Title 18, United States Code, Section 981(a) (1) (C) and Title 28, United States Code, S.ection 2461, any and all - 78 - property constituting, and derived from, proceeds obtained directly and indirectly as a result of such violations. 99. As a result of the illegal gambling business offenses alleged in Counts Five, Nine, Sixteen and Twenty of this Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, JUSTIN SMITH, WILLIAM EDLER, PETER FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a "D.A.," BRYAN ZURIFF, ABRAHAM MOSSERI, DMITRY DRUZHINSKY, ALEXANDER ZAVE RUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a "Murashka," ARTHUR AZEN, KIRILL RAPOPORT, MOSHE ORATZ, EUGENE TRINCHER, EDWIN TING, a/k/a "Eddie," JOSEPH MANCUSO, WILLIAM BARBALAT, YUGESHWAR RAJ KUMAR , a/k/a "Mateo Hermatte," MOLLY BLOOM, the defendants, shall forfeit to the United States pursuant to Title 18, United States Code, Section 1955(d), any property, including money, used in such violations. Substitute Asset Provision 100. If any of the above-described forfeitable property, as a result of any act or omission of the defendants: a. cannot be located upon the exercise of due b. has been transferred or sold to, or diligence; deposited with, a third person; - 79 - c. has been placed beyond the jurisdiction of d. has been substantially diminished in value; e. has been commingled with other property the Court; or which cannot be subdivided without difficulty, it is the intent of the united States, pursuant to Title 21, United States Code, Section 853 (p), to seek forfeiture of any other property of said defendants up to the value of the abovedescribed forfeitable property. (Title 18, United States Code, Section 981 and 1955; Title 21, United States Code, Section 853; and Title 28, United States Code, Section 2461.) Forfeiture Allegation as to Counts Seven, Twelve, and Eighteen 101. As a result of committing the money laundering offenses alleged in Counts Seven, Twelve, Eighteen of this Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, DMITRY DRUZHINSKY, ALEXANDER ZAVERUKHA, a/k/a "Sasha," EUGENE TRINCHER, EDWIN TING, a/k/a "Eddie," PETER SKYLLAS, RONALD UY, DON MCCALMONT, ILYA ROSENFELD, and ANATOLY SHTEYNGRAB, the defendants, shall forfeit to the united States pursuant to Title - 80 - 18, United States Code, Section 982(a) (1), any property, real or personal, involved in such offense, or any property traceable to such property. Substitute Asset Provision 102. If any of the above-described forfeitable property, as a result of any act or omission of the defendants: a. cannot be located upon the exercise of due b. has been transferred or sold to, or diligence; deposited with, a third person; c. has been placed beyond the jurisdiction of d. has been substantially diminished in value; e. has been commingled with other property the Court; or which cannot be subdivided without difficulty, it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of said defendants up to the value of the abovedescribed forfeitable property. (Title 18, United States Code, Section 982; and Title 21, United States Code, Section 853.) Forfeiture Allegation as to Count Thirteen - 81 - 103. As a result of committing the structuring offense alleged in Count Thirteen of this Indictment, RONALD UY and ILLYA TRINCHER, the defendants, shall forfeit to the United States pursuant to Title 31, United States Code, Section 5317(c), all property, real or personal, involved in such offense, or any property traceable to such property. Substitute Asset Provision 104. If any of the above-described forfeitable property, as a result of any act or omission of the defendants: a. cannot be located upon the exercise of due b. has been transferred or sold to, or diligence; deposited with; a third person; c. has been placed beyond the jurisdiction of d. has been substantially diminished in value; e. has been commingled with other property the Court; or which cannot be subdivided without difficulty, it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any - 82 - other property of said defendants up to the value of the abovedescribed forfeitable property. (31, United States Code, Section 5317(c); and Title 21, United States Code, Section 853.) PREET BHARARA United States Attorney - 83 - UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA - v. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, STAN GREENBERG, a/k/a "Slava," ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," JOHN HANSON, NOAH SIEGEL, a/k/a "The Oracle," JONATHAN HIRSCH, ARTHUR AZEN, DONALD MCCALMONT, DMITRY DRUZHINSKY, a/k/a "Dima," a/k/a "Blondie," ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a "Murushka," ANATOLY SHTEYNGROB, a/k/a "Tony," ILYA ROZENFELD, PETER SKYLLAS, RONALD UY, NICHOLAS HIRSCH, BRYAN ZURIFF, MOSHE ORATZ, KIRILL RAPOPORT, DAVID AARON, a/k/a "D.A.," JUSTIN SMITH, ABRAHAM MOSSERI, WILLIAM EDLER, PETER FELDMAN, EUGENE TRINCHER, EDWIN TING, a/k/a "Eddie," MOLLY BLOOM, WILLIAM BARBALAT, YUGESHWAR RAJKUMAR, a/k/a "Mateo Hermatte," and JOSEPH MANCUSO,a/k/a "Joe the Hammer," Defendants. SEALED INDICTMENT 13 Cr. (18 U.S.C. ?? 894, 1084, 1951, 1952, 1955, 1956, 1962, and 2; 31 U.S.C. ?? 5324, 5363, and 5366.) PREET BHARARA United States A~torney. / on.