Case 1:18-cr-00509-GBD Document 779 Filed 10/15/20 Page 1 of 7
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`UNITED STATES DISTRI CT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMER I CA
`
`- v . -
`
`I GOR STASOVSKIY ,
`
`Defendant .
`
`X
`
`X
`
`SEALED
`SUPERSEDING IN FORMATION
`
`Sl4 18 Cr . 509
`
`(GBD)
`
`COUNT ONE
`(Conspiracy to Commit Wire Fraud)
`
`The United States Attorney charges :
`
`1 .
`
`From at l east in or about September 2016 , up to i n or
`
`about July 2018 ,
`
`in
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`the Southern District of New York and
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`e l sewhere ,
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`IGOR STASOVSKIY ,
`
`the defendant , and others known and
`
`unknown , willfully
`
`and
`
`knowing l y ,
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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
`
`fraud ,
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`i n violation of Title 18 , United States Code , Section 1343 .
`
`2 .
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`It was a part and object of the conspiracy that IGOR
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`STASOVSKIY , the defendant , and others known and unknown , willfully
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`and knowingly , having devised and intending to devise a scheme and
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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 ,
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`and
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`television communication
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`in interstate and foreign
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`commerce , writings, signs, signals , pictures , and sounds for the
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`
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`purpose of executing such scheme and artifice , in v i o l ation of Title
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`18 , Un i ted States Code , Sect ion 1343 .
`
`(Title 18 , United States Code , Section 1349 . )
`
`COUNT TWO
`(Wire Fraud)
`
`The United States Attorney further charges :
`
`3.
`
`From at least in or about September 2016 , up to in or
`
`about July 2018 ,
`
`in
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`the Southern District of New York and
`
`elsewhere ,
`
`IGOR
`
`STASOVSKIY ,
`
`the defendant , willfully
`
`and
`
`knowingly , having devised and intending to devise a scheme and
`
`artifice to defra u d , and for obtaining money and property by means
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`of false and fraudulent pretenses , representations , and promi ses ,
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`did transmit and cause to be transmitted by means of wire , radio ,
`
`and television communication in interstate and foreign commerce ,
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`writings , signs , signals , pictures , and sounds , for the purpose of
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`executing
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`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
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`the internet and to misappropriate
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`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
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`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 . )
`
`2
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`
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`COUNT THREE
`(Conspiracy to Commit Money Laundering)
`
`The United States Attorney further charges :
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`4 .
`
`From at least in or about September 2016 , up to in or
`
`about July 2018 ,
`
`in
`
`the Southern District of New York and
`
`elsewhere ,
`
`IGOR STASOVSKIY ,
`
`the defendant , and others known and
`
`unknown , willfully
`
`and
`
`knowingly
`
`did
`
`combine ,
`
`conspire ,
`
`confederate , and agree together and with each other to commit money
`
`laundering in violation of Title 18 , Un i ted States Code , Sections
`
`1956(a) (1) (B) (i) and 1956(a) (2) (B) (i) .
`
`5.
`
`It was a part and an object of the conspiracy that IGOR
`
`STASOVSKIY ,
`
`the defendant , and others known and unknown ,
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`in an
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`offense involving and affecting interstate and foreign commerce ,
`
`knowing
`
`that the property
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`involved
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`in a
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`financial
`
`transaction
`
`represented the proceeds of some form of unlawful activity , would
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`and did conduct and attempt to conduct such a financial transaction
`
`which in fact involved the proceeds of specif i ed unlawful activity
`
`as defined in 18 U.S . C .
`
`§ 1956(c) (7) (A)
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`&
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`(B) ,
`
`to wit ,
`
`the wire
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`fraud conspiracy and wire fraud , as charged in Counts One and Two
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`of this Information , knowing that the transaction was designed in
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`whole and in part to conceal and disguise the nature , the location ,
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`the source,
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`the ownership , and the control of the proceeds of
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`specified unlawful activity in violation of Title 18 , 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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`IGOR STASOVSKIY , 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 ,
`
`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
`
`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 ,
`
`and transfer represent_ed the proceeds of some
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`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
`
`of the proceeds of specified unlawful activity ,
`
`to wit, the wire
`
`fraud conspiracy and wire fraud charged in Counts One and Two of
`
`this Information ,
`
`in violation of Title 18 , United States Code ,
`
`Section 1956(a) (2) (B) (i) .
`
`(Title 18 , United States Code, Section 1956(h) . )
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`FORFEITURE ALLEGATIONS
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`7 .
`
`As a result of committing the offenses alleged in Counts
`
`One and Two of this Information ,
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`IGOR STASOVSKIY,
`
`the defendant ,
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`shall forfeit to the United States , pursuant to Title 18 , United
`
`States Code , Section 981 (a) (1) (C) and Title 28 , United States Code ,
`
`Section 2461 (c) , any and all property ,
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`real and personal,
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`that
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`4
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`constitutes or is derived from proceeds traceable to the commission
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`of said offenses ,
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`including but not limited to a sum of money in
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`United States currency representing the amount of proceeds traceable
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`to the 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 ,
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`IGOR STASOVSKIY ,
`
`the _ defendant , shall
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`forfeit to the United States, pursuant to Title 18 , United States
`
`Code , Section 982 (a) (1) , any and all property , real and personal ,
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`involved in said offense , or any property traceable to such property ,
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`including but not limited to a sum of money in United States currency
`
`representing the amount of property involved in said offense .
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`SUBSTITUTE ASSET PROVISION
`
`9 .
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`If any of the above - described forfeitable property , as a
`
`result of any act or omission of the defendant :
`
`a .
`
`cannot be located upon the exercise of due
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`diligence ;
`
`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
`
`e.
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`has been commingled with other property which
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`cannot be divided without difficulty ;
`
`it is the intent of the United States, pursuant to Title 21 ,
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`5
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`United States Code , Section 853(p) and Title 28 , United States
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`Code, Section 2461(c) , to seek forfeiture of any other property of
`
`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 . )
`
`es Attorney
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`6
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`
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`Case 1:18-cr-00509-GBD Document 779 Filed 10/15/20 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.
`
`IGOR STASOVSKIY,
`
`Defendant.
`
`SEALED SUPERSEDING INFORMATION
`
`S14 18 Cr . 509
`
`(GBD)
`
`(18 U.S . C . §§ 1349 , 1343 , 1956 , and 2 . )
`
`GEOFFREY S . BERMAN
`United States Attorney
`
`
