Case 1:18-cr-00509-GBD Document 616 Filed 07/07/20 Page 1 of 7
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`UNITED STATES OF AMERICA
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`- v. -
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`ROMAN DEGTEV,
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`Defendant.
`
`X
`
`X
`
`SUPERSEDING INFORMATION
`
`Sl2 18 Cr. 509 (GBD)
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`COUNT ONE
`(Conspiracy to Commit Wire Fraud)
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`The United States Attorney charges:
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`1.
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`From at least in or about November 2016, up to and
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`including the present, in the Southern District of New York and
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`elsewhere, ROMAN DEGTEV,
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`the defendant, and others known and
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`unknown, willfully
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`and
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`knowingly,
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`did
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`combine,
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`conspire,
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`confederate, and agree together and with each other to commit wire
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`fraud, in violation of Title 18, United States Code, Section 1343.
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`2.
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`It was a part and object of the conspiracy that ROMAN
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`DEGTEV,
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`the defendant, and others known and unknown, willfully and
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`knowingly, having devised and intending to devise a scheme and
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`'·
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`artifice to defraud and for obtaining money and property by means
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`of false and fraudulent pretenses, representations, and promises,
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`would and did transmit and cause to be transmitted by means of wire,
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`radio, and
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`television communication in interstate and foreign
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`commerce, writings, signs, signals, pictures, and sounds for the
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`Case 1:18-cr-00509-GBD Document 616 Filed 07/07/20 Page 2 of 7
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`purpose of executing such scheme and artifice, in violation of Title
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`18, United States Code, Section 1343.
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`(Title 18, United States Code, Section 1349.)
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`COUNT TWO
`(Wire Fraud)
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`The United States Attorney further charges:
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`3.
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`From at least in or about November 2016, up to and
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`including the present, in the Southern District of New York and
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`elsewhere, ROMAN DEGTEV,
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`the defendant, willfully and knowingly,
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`having devised and intending to devise a scheme and artifice to
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`defraud, and for obtaining money and property by means of false
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`and fraudulent pretenses,
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`representations, and promises, did
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`transmit and cause to be transmitted by means of wire, radio, and
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`television communication
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`in interstate and foreign commerce,
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`writings, signs, signals, pictures, and sounds, for the purpose of
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`executing such
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`scheme and artifice,
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`to wit,
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`the defendant
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`participated in a scheme to induce buyers to make wire payments
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`for the purported purchase of automobiles, boats, and machinery
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`falsely advertised on the internet and to misappropriate the
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`buyers' payments, and in connection therewith and in furtherance
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`thereof,
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`transmitted and caused to be
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`transmitted interstate
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`electronic mail, telephone calls, and wire transfers of funds.
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`(Title 18, United States Code, Sections 1343 and 2.)
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`2
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`Case 1:18-cr-00509-GBD Document 616 Filed 07/07/20 Page 3 of 7
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`COUNT THREE
`(Conspiracy to Commit Money Laundering)
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`The United States Attorney further charges:
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`4.
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`From at least in or about November 2016, up to and
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`including the present, in the Southern District of New York and
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`elsewhere, ROMAN DEGTEV,
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`the defendant, and others known and
`
`unknown, willfully
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`and
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`knowingly
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`did
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`combine,
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`conspire,
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`confederate, and agree together and with each other to commit money
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`laundering in violation of Title 18, United States Code, Section
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`19 5 6 (a) ( 1 ) ( B) ( i) and 19 5 6 (a) ( 2 ) ( B) ( i ) .
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`5.
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`It was a part and an object of the conspiracy that ROMAN
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`DEGTEV,
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`the defendant, and others known and unknown, in an offense
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`involving and affecting interstate and foreign commerce, knowing
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`that the property involved in a financial transaction represented
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`the procee9-s of some form of unlawful activity, would and did
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`conduct and attempt to conduct such a financial transaction which
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`in fact involved the proceeds of specified unlawful activity as
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`defined in 18 U.S.C. § 1956(c) (7) (A) & (B), to wit, the proceeds of
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`the wire fraud conspiracy and wire fraud, as.charged in Counts One
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`and Two of this Information, knowing that the transaction was
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`designed in whole and in part to conceal and disguise the nature,
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`the location, the source, the ownership, and the control o·f the
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`proceeds of specified unlawful activity in violation of Title 18,
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`United States Code, Section 1956(a) (1) (B) (i).
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`3
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`.
`' .
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`6.
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`It was a further part and object of the conspiracy that
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`ROMAN DEGTEV,
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`the defendant, and others known and unknown, in an
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`offense involving and affecting interstate and foreign commerce
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`transported,
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`transmitted,
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`and
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`transferred,
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`and attempted
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`to
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`transport, transmit, and transfer a monetary instrument and funds
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`from a place in the United States to and through a place outside
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`the United States and to a place in the United States from and
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`through a place outside the United States, knowing that the monetary
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`instrument and funds involved in the transportation, transmission,
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`and transfer represented the proceeds of some form of unlawful
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`activity and knowing that such transportation,
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`transmission, and
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`transfer was designed in whole and in part to conceal and disguise
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`the nature, the location, the source, the ownership, and the control
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`of the proceeds of specified unlawful activity, to wit, the wire
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`fraud conspiracy and wire fraud charged in Counts One and Two of
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`this Information,
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`in violation of Title 18, United States Code,
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`Section 1956 (a) (2) (B) (i)
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`(Title 18, United States Code, Section 1956(h) .)
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`FORFEITURE ALLEGATIONS
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`7.
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`As a result of committing the offenses alleged in Counts
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`One and Two of this Information, ROMAN DEGTEV, the defendant, shall
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`forfeit to the United States, pursuant to Title 18, United States
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`Code, Section 98l(a) (1) (C) and Title 28, United States Code, Section
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`246l(c), any and all property, real and personal, that constitutes
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`4
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`Case 1:18-cr-00509-GBD Document 616 Filed 07/07/20 Page 5 of 7
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`or is derived from proceeds traceable to the commission of said
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`offenses,
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`including but not limited to a sum of money in United
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`States currency representing the amount of proceeds traceable to the
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`commission of said offenses.
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`8.
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`As a result of committing the offense alleged in Count
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`Three of this Information, ROMAN DEGTEV, the defendant, shall forfeit
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`to the United States, pursuant to Tit.le 18, United States Code,
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`Section 982(a) (1), any and all property, real and personal, involved
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`in said offense, or any property traceable
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`to such property,·
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`including but not limited to a sum of money in United States currency
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`representing the amount of property involved in said offense.
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`SUBSTITUTE ASSET PROVISION
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`9.
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`If any of the above-described forfeitable property, as a
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`result of any act or omission of the defendant:
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`a.
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`cannot be located upon the exercise of due
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`diligence;
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`b.
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`has been transferred or sold to, or deposited with,
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`a third party;
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`c.
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`has been placed beyond the jurisdiction of the
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`court;
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`d.
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`has been substantially diminished in value; or
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`e.
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`has been commingled with other property which
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`cannot be divided without difficulty;
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`it is the intent of the United States, pursuant to Title 21,
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`5
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`'}
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`,1'11'
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`Case 1:18-cr-00509-GBD Document 616 Filed 07/07/20 Page 6 of 7
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`United States Code, Section 853(p) and Title 28, United States
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`Code, Section 246l(c), to seek forfeiture of any other property of
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`the defendant up to the value of the forfeitable property
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`described above.
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`(Title 18, United States Code, Sections 981, 982; Title 21,
`United States Code, Section 853; and Title 28, United States
`Code, Section 2461.)
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`Gm.t~
`
`United States Attorney
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`6
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`Case 1:18-cr-00509-GBD Document 616 Filed 07/07/20 Page 7 of 7
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`Form No. USA-33s-274 (Ed. 9-25-58)
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMERICA
`
`v.
`
`ROMAN DEGTEV,
`
`Defendant.
`
`SUPERSEDING INFORMATION
`
`S12 18 Cr. 509 (GBD)
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`(18 U.S.C. §§ 1349, 1343, 1956, and 2).
`
`GEOFFREY S. BERMAN
`United States Attorney
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`
