Case 1:23-cr-00118-AT Document 612-2 Filed 04/04/25 Page 1 of 6
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMERICA
`
`
`v.
`
`HO WAN KWOK,
` a/k/a “Miles Guo,”
` a/k/a “Miles Kwok,”
` a/k/a “Guo Wengui,”
` a/k/a “Brother Seven,”
` a/k/a “The Principal,”
`
`KIN MING JE,
` a/k/a “William Je,” and
`
`YANPING WANG,
` a/k/a “Yvette,”
`
`
`
`
`
`
`
`GOVERNMENT’S FORFEITURE
`BILL OF PARTICULARS
`
`S1 23 Cr. 118 (AT)
`
`
`
`
`Defendants.
`
`Pursuant to United States v. Grammatikos, 633 F.2d 1013, 1024 (2d Cir. 1980),
`
`the Government respectfully gives notice that the property subject to forfeiture as a result of the
`
`offenses described in Counts One through Eleven of Indictment S1 23 Cr. 118 (AT) charging HO
`
`WAN KWOK, a/k/a “Miles Guo,” a/k/a “Miles Kwok,” a/k/a “Guo Wengui,” a/k/a “Brother
`
`Seven,” a/k/a “The Principal,” KIN MING JE, a/k/a “William Je,” and YANPING WANG, a/k/a
`
`“Yvette” (the “Defendants”), and as alleged in the forfeiture allegations and/or substitute asset
`
`provision therein, includes the following:
`
`a. $64,826.87 in United States currency formerly on deposit in Account
`
`Number 5090037713 at Silvergate Bank held in the name of “Hamilton Opportunity Fund SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`1
`
`
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMERICA
`
`
`v.
`
`HO WAN KWOK,
` a/k/a “Miles Guo,”
` a/k/a “Miles Kwok,”
` a/k/a “Guo Wengui,”
` a/k/a “Brother Seven,”
` a/k/a “The Principal,”
`
`KIN MING JE,
` a/k/a “William Je,” and
`
`YANPING WANG,
` a/k/a “Yvette,”
`
`
`
`
`
`
`
`GOVERNMENT’S FORFEITURE
`BILL OF PARTICULARS
`
`S1 23 Cr. 118 (AT)
`
`
`
`
`Defendants.
`
`Pursuant to United States v. Grammatikos, 633 F.2d 1013, 1024 (2d Cir. 1980),
`
`the Government respectfully gives notice that the property subject to forfeiture as a result of the
`
`offenses described in Counts One through Eleven of Indictment S1 23 Cr. 118 (AT) charging HO
`
`WAN KWOK, a/k/a “Miles Guo,” a/k/a “Miles Kwok,” a/k/a “Guo Wengui,” a/k/a “Brother
`
`Seven,” a/k/a “The Principal,” KIN MING JE, a/k/a “William Je,” and YANPING WANG, a/k/a
`
`“Yvette” (the “Defendants”), and as alleged in the forfeiture allegations and/or substitute asset
`
`provision therein, includes the following:
`
`a. $64,826.87 in United States currency formerly on deposit in Account
`
`Number 5090037713 at Silvergate Bank held in the name of “Hamilton Opportunity Fund SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`1
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`Case 1:23-cr-00118-AT Document 612-2 Filed 04/04/25 Page 2 of 6
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`b. $75,000,000.00 in United States currency formerly on deposit in Account
`
`Number 5090037705 at Silvergate Bank held in the name of “Hamilton Opportunity Fund SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`c. $467,343.00 in United States currency formerly on deposit in Account
`
`Number 5090037754 at Silvergate Bank held in the name of “Hamilton Opportunity Fund SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`d. $89,992,861.75 in United States currency formerly on deposit in Account
`
`Number 5090042770 at Silvergate Bank held in the name of “Hamilton Opportunity Fund SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`e. $1,683,077.40 in United States currency formerly on deposit in Account
`
`Number 5090042762 at Silvergate Bank held in the name of “Hamilton Opportunity Fund SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`f. $85,899,889.20 in United States currency formerly on deposit in Account
`
`Number 5090042853 at Silvergate Bank held in the name of “Hamilton Opportunity Funds SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`g. $48,230,709.62 in United States currency formerly on deposit in Account
`
`Number 5090030288 at Silvergate Bank held in the name of “Hamilton Investment Management”
`
`Ltd., seized by the Government on or about September 18, 2022;
`
`h. $1,800,000.00 in United States currency formerly on deposit in Account
`
`Number 5090037739 at Silvergate Bank held in the name of “Hamilton Opportunity Fund SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`2
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`Case 1:23-cr-00118-AT Document 612-2 Filed 04/04/25 Page 3 of 6
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`i. $85,899,889.20 in United States currency formerly on deposit in Account
`
`Number 5090042853 at Silvergate Bank held in the name of “Hamilton Opportunity Funds SPC,”
`
`seized by the Government on or about September 18, 2022;
`
`
`
`j. $4,643,744.70 in United States currency formerly on deposit in Account j. $4,643,744.70 in United States currency formerly on deposit in Account
`
`
`
`Number 7801000590 at FV Bank held in the name of “Himalaya International Reserves, Ltd.,” Number 7801000590 at FV Bank held in the name of “Himalaya International Reserves, Ltd.,”
`
`
`
`seized by the Government on or about September 20, 2022; seized by the Government on or about September 20, 2022;
`
`
`
`k. $14,599,257.25 in United States currency formerly on deposit in Account k. $14,599,257.25 in United States currency formerly on deposit in Account
`
`
`
`Number 7801000254 at FV Bank held in the name of “Himalaya International Clearing, Ltd.,” Number 7801000254 at FV Bank held in the name of “Himalaya International Clearing, Ltd.,”
`
`
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`seized by the Government on or about September 20, 2022;seized by the Government on or about September 20, 2022;
`
`
`
`l. $7,715.00, in United States currency formerly on deposit in Account l. $7,715.00, in United States currency formerly on deposit in Account
`
`
`
`Number 7801000589 at FV Bank held in the name of “Himalaya International Financial Group, Number 7801000589 at FV Bank held in the name of “Himalaya International Financial Group,
`
`
`
`Ltd.,” seized by the Government on or about September 20, 2022;Ltd.,” seized by the Government on or about September 20, 2022;
`
`m. $11,538,579.87 in United States currency formerly on deposit in Account
`
`Number MBI10103-0000 at Mercantile Bank International held in the name of “G Club
`
`International Ltd.,” seized by the Government on or about October 16, 2022;
`
`
`
`n. $10,008,284.04 in United States currency formerly on deposit in Account n. $10,008,284.04 in United States currency formerly on deposit in Account
`
`
`
`Number MBI10133-0000 at Mercantile Bank International held in the name of “Himalaya Number MBI10133-0000 at Mercantile Bank International held in the name of “Himalaya
`
`
`
`International Clearing Ltd.,” seized by the Government between on or about October 16, 2022 and International Clearing Ltd.,” seized by the Government between on or about October 16, 2022 and
`
`
`
`on or about March 10, 2023;on or about March 10, 2023;
`
`o. $3,090,856.54 in United States currency formerly on deposit in Account
`
`Number MBI10137-0000 at Mercantile Bank International held in the name of “Hamilton Capital
`
`3
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`Case 1:23-cr-00118-AT Document 612-2 Filed 04/04/25 Page 4 of 6
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`Holding Ltd.,” seized by the Government between on or about October 16, 2022 and on or about
`
`March 10, 2023;
`
`
`
`p. $272,350,313.76 in United States currency formerly on deposit in Account p. $272,350,313.76 in United States currency formerly on deposit in Account
`
`
`
`Number MBI10138-0000 at Mercantile Bank International held in the name of “Himalaya Number MBI10138-0000 at Mercantile Bank International held in the name of “Himalaya
`
`
`
`International Reserves Ltd.,” seized by the Government between on or about October 16, 2022 and International Reserves Ltd.,” seized by the Government between on or about October 16, 2022 and
`
`
`
`on or about March 10, 2023;on or about March 10, 2023;
`
`
`
`q. $310,594.31 in United States currency formerly on deposit in Account q. $310,594.31 in United States currency formerly on deposit in Account
`
`
`
`Number MBI10139-0000 at Mercantile Bank International held in the name of “Himalaya Number MBI10139-0000 at Mercantile Bank International held in the name of “Himalaya
`
`
`
`International Financial Group Ltd.,” seized by the Government between on or about October 16, International Financial Group Ltd.,” seized by the Government between on or about October 16,
`
`
`
`2022 and on or about March 10, 2023; 2022 and on or about March 10, 2023;
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`r. $1,187,278.87 in United States currency formerly on deposit in Account
`
`Number MBI10171-0000 at Mercantile Bank International held in the name of “Hamilton
`
`Investment Management Ltd.,” seized by the Government between on or about October 16, 2022
`
`and on or about March 10, 2023;
`
`s. $43,782.71 in United States currency formerly on deposit in Account
`
`Number MBI10172-0000 at Mercantile Bank International held in the name of “G Fashion
`
`International Limited,” seized by the Government on or about October 16, 2022;
`
`
`
`t. $161,809.47 in United States currency formerly on deposit in Account t. $161,809.47 in United States currency formerly on deposit in Account
`
`
`
`Number MBI10183-0000 at Mercantile Bank International held in the name of “Himalaya Number MBI10183-0000 at Mercantile Bank International held in the name of “Himalaya
`
`
`
`Currency Clearing Pty Ltd.,” seized by the Government on or about October 16, 2022;Currency Clearing Pty Ltd.,” seized by the Government on or about October 16, 2022;
`
`4
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`Case 1:23-cr-00118-AT Document 612-2 Filed 04/04/25 Page 5 of 6
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`u. $2,745,377.75 in United States currency formerly on deposit in Account
`
`Number 9878904409 at Manufacturers & Traders Trust Co. held in the name of “GETTR USA,
`
`Inc.,” seized by the Government on or about September 18, 2022;
`
`v. $9,899,659.19 in United States currency formerly on deposit in Account
`
`Number 157525208185 at US Bank held in the name of “G Fashion,” seized by the Government
`
`on or about September 18, 2022;
`
`w. All that lot or parcel of land, together with its buildings, appurtenances,
`
`improvements, fixtures, attachments, and easements, located at 675 Ramapo Valley Road,
`
`Mahwah, New Jersey 07430, Parcel No. 3300021-03-00001-02 and described as Lot Number: 1.02
`
`Block: 21.03 District: 33 City, Municipality, Township: MAHWAH TWP
`
`x. A Bugatti Chiron Super Sport, bearing Vehicle Identification Number
`
`VF9SW3V3XNM795047;
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`y. A Lamborghini Aventador SVJ Roads, bearing Vehicle Identification
`
`Number ZHWUN6ZD2MLA10393;
`
`z. A Rolls Royce Phantom EWB, bearing Vehicle Identification Number
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`SCATT8C08MU206445;
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`aa. A 46m 2014 Feadship superyacht “Lady May” (ex Como), bearing IMO
`
`Number 112359, MMSI Number 319059500, and Callsign ZGDQ9;
`
`bb. A Bösendorfer 185VC Porsche #49539 piano with custom bench, purchased
`
`for approximately $140,938.69;
`
`cc. A Railis Design Iceland Contemporary Poseidon Bed with Nightstands,
`
`Ebony Veneer, Brass, Velvet, purchased for approximately $31,413.71;
`
`5
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`Case 1:23-cr-00118-AT Document 612-2 Filed 04/04/25 Page 6 of 6
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`dd. A Hästens 2000T md mattress, purchased for approximately $36,590.00;
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`ee. A Hästens 2000T sf mattress, purchased for approximately $36,210.00;
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`ff. A Wembe watch storage box, purchased for approximately $59,392.91;
`
`gg. A Samsung Q900 Series QN98Q900RBF 98” QLED Smart TV – 8K,
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`purchased for approximately $62,787.54;
`
`hh. A Louis XV Style French Ormolu-Mounted Mahogany Commode by
`
`Joseph Émmanuel Zweiner;
`
`ii. A “K’ang Hsi” extension table in etched and patinated pewter and bronze
`
`with hand-painted enamel colors by Philip & Kelvin LaVerne, purchased for approximately
`
`$180,000.00; and
`
`jj. A “Punto ‘83” table in stainless steel with mesh tabletop with adjustable
`
`height and adjustable petals by Gabriella Crespi, Italy 1982, purchased for approximately
`
`$180,000.00.
`
`Dated:
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`
`
`New York, New York
`April 7, 2023
`
`Respectfully Submitted,
`
`DAMIAN WILLIAMS
`United States Attorney
`
`By:
`
`
`
`Micah F. Fergenson
`Ryan B. Finkel
`Juliana N. Murray
`Assistant United States Attorney
`(212) 637-2190 / 6612 / 2314
`
`6
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