USA V Abbas July 2020 Information

Case 2:20-cr-00322-ODW Document 11 Filed 07/29/20 Page 1 of 17 Page ID #:61
7/29/2020
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8 UNITED STATES DISTRICT COURT
9 FOR THE CENTRAL DISTRICT OF CALIFORNIA
10
UNITED STATES OF AMERICA, CR No. 2:20-cr-00322-ODW
11
Plaintiff, I N F O R M A T I O N
12
v. [18 U.S.C. § 1349: Conspiracy to
13 Commit Wire Fraud; 18 U.S.C.
RAMON OLORUNWA ABBAS, § 1956(h): Conspiracy to Engage in
14 aka “Ray Hushpuppi,” Money Laundering; 18 U.S.C.
aka “Hush,” § 1956(a)(2)(B)(i): International
15 Money Laundering; 18 U.S.C.
Defendant. § 1957: Engaging in Monetary
16 Transactions in Property Derived
from Specified Unlawful Activity;
17 18 U.S.C. § 2(a): Aiding and
Abetting; 18 U.S.C. §§ 981 and 982
18 and 28 U.S.C. § 2461(c): Criminal
Forfeiture]
19
20 The United States Attorney charges:

21 INTRODUCTORY ALLEGATIONS
22 At times relevant to this Information:
23 A. Defendant
24 1. Defendant RAMON OLORUNWA ABBAS, also known as (“aka”) “Ray
25 Hushpuppi,” aka “Hush,” (“ABBAS”), was a resident of the United Arab
26 Emirates.
27 //
28 //
1 B. Bank Accounts
2 2. The “Chase Account” was a bank account held at JP Morgan
3 Chase Bank, N.A. (“Chase”), with the account number ending in 6628,
4 which was held in Pearland, Texas.
5 3. The “CIBC Account” was a bank account held at Canadian
6 Imperial Bank of Commerce, with the account number ending in 1716,
7 which was held in Ontario, Canada.
8 C. Victims
9 4. The “Victim Law Firm” was a law firm in the State of New
10 York.
11 5. The “Foreign Financial Institution” was a foreign bank
12 located in a European country (the “European Country”).
13 6. The “Victim English Premier League Club” was a professional
14 soccer club located in the United Kingdom.
15 7. The “Victim U.K. Company” was a company located in the
16 United Kingdom.
17 D. Terminology
18 8. A business email compromise (“BEC”) fraud occurs when a
19 hacker gains unauthorized access to an email account used by a
20 business or company, blocks or redirects communications to and/or
21 from the email account, and then uses the compromised email account
22 or a separate fraudulent email account to communicate with personnel
23 from a victim company (which may be the company to which the
24 compromised account belongs, or another company doing business with
25 that company), attempting to trick the victim-company personnel into
26 making an unauthorized wire transfer.
27 9. A cyber-heist occurs where a hacker gains access to the
28 computer(s) of a bank without authorization and sends messages
2
1 through the Society for Worldwide Interbank Financial
2 Telecommunication (“SWIFT”) communication system from the victim
3 bank’s computer system, authorizing and causing fraudulent wire
4 transfers to bank accounts used and controlled by conspirators.
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1 COUNT ONE
2 [18 U.S.C. § 1349]
3 10. The United States Attorney re-alleges and incorporates here
4 paragraphs 1 through 9 of the Introductory Allegations of this
5 Information.
6 A. OBJECT OF THE CONSPIRACY
7 11. Beginning on an unknown date, but no later than on or about

8 January 16, 2019, and continuing until on or about October 17, 2019,
9 in Los Angeles County, within the Central District of California, and
10 elsewhere, defendant ABBAS, and unindicted coconspirator #1 (“UICC
11 1”) and unindicted coconspirator #2 (“UICC 2”), together with others
12 known and unknown to the United States Attorney, knowingly conspired
13 to commit wire fraud, in violation of Title 18, United States Code,
14 Section 1343.
15 B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE
16 ACCOMPLISHED
17 12. The objects of the conspiracy were to be accomplished, in
18 substance, as follows:
19 a. Defendant ABBAS and UICC 1 would request from each
20 other a bank account or bank accounts that could be used to receive
21 fraudulently obtained funds, including funds that defendant ABBAS and
22 UICC 1 knew were obtained from BEC and cyber-heist schemes through
23 false or fraudulent pretenses, representations, and promises, and
24 concealment of material facts.
25 b. Defendant ABBAS and UICC 1 would, in response to such
26 an inquiry, send to each other account information for a bank account
27 or bank accounts that could be used to receive fraudulently obtained
28 funds. For such a bank account, defendant ABBAS and UICC 1 would, at
4
1 a minimum, send the bank account number and the SWIFT code, or the
2 international bank account number (“IBAN”). The bank account would
3 be opened in the name of a coconspirator or other person, to hide the
4 fraudulent nature of the deposit, wire, or transfer, and to conceal
5 and disguise the nature, location, source, ownership, and control of
6 the proceeds, but would be used or controlled, directly or
7 indirectly, by defendant ABBAS or UICC 1.
8 c. Defendant ABBAS and UICC 1, or their coconspirators,
9 would, through false or fraudulent pretenses, representations, and
10 promises, and concealment of material facts, cause a victim to
11 deposit, wire, or transfer funds into the bank account(s) that had
12 been identified.
13 i. In a BEC fraud scheme, a coconspirator would
14 communicate with the victim-company -- fraudulently pretending to be
15 a company doing business with the victim-company -- and would provide
16 the victim-company with instructions to wire transfer a payment to
17 the bank account(s) identified to receive fraudulently obtained
18 funds.
19 ii. In a cyber-heist scheme, a coconspirator would
20 fraudulently send a message through the SWIFT system of the victim-
21 bank, directing a wire transfer from the victim-bank to the bank
22 account(s) identified to receive fraudulently obtained funds.
23 d. Defendant ABBAS and UICC 1, or their coconspirators,
24 would withdraw the fraudulently obtained funds from the bank account,
25 and would further launder the funds through wire transfer(s) to
26 additional bank accounts in the names of persons other than defendant
27 ABBAS and UICC 1 and through other withdrawals -- sometimes with the
28 assistance of additional coconspirators, such as UICC 2 -- so as to
5
1 obtain the money and so as to conceal and disguise the nature,
2 location, source, ownership, and control of the proceeds.
3 e. Defendant ABBAS and UICC 1 attempted to fraudulently
4 obtain and launder hundreds of millions of dollars in this manner.
5 C. OVERT ACTS
6 13. In furtherance of the conspiracy, and to accomplish its

7 objects, defendant ABBAS, and UICC 1 and UICC 2, together with others
8 known and unknown to the United States Attorney, on or about the
9 dates set forth below, committed and caused to be committed various
10 overt acts, in the Central District of California and elsewhere,
11 including, but not limited to, the following:
12 Overt Act No. 1: On or about January 18, 2019, in response to
13 requests by UICC 1 for two bank accounts that could each receive €5
14 million wire transfers from a bank in the European Country, defendant
15 ABBAS sent electronic messages providing the account information for
16 a bank account in Romania, including the IBANs, and wrote, “I look
17 forward from great result[.]”
19 a request by UICC 1 about the “maximum amount” the Romanian bank
20 account could “handle in 24hr,” defendant ABBAS sent an electronic
21 message stating, “It’s for large amounts[.]”
23 statements by UICC 1 that “[m]y associates want u to clear as soon it
24 hits . . . Cuz a recall can be,” and “if they don’t notice we keep
25 pumping,” defendant ABBAS sent an electronic message stating, “Good.”
26 Overt Act No. 4: On or about February 10, 2019, after UICC 1
27 had told defendant ABBAS that he had “6 slots in total [¶] all 5m
28 euro,” and needed additional bank accounts to receive “big hit in
6
1 12th feb” that would “all credit same time,” defendant ABBAS, in an
2 electronic message, provided the account information for a bank
3 account in Bulgaria, including the IBANs.
5 had told defendant ABBAS that €500,000 had been wired to the Romanian
6 bank account that defendant ABBAS had provided, defendant ABBAS
7 stated, in an electronic message, “Ok let me hit my people up.”
9 told defendant ABBAS that the fraudulent wire transfer of €500,000
10 had come from the Foreign Financial Institution, and that “we still
11 have access and they didn’t realize , we gonna shoot again tomoro
12 am,” defendant ABBAS confirmed, through an electronic message, that
13 UICC 1 should continue to use the Romanian bank account to receive
14 funds, stating, “Yes please[.]”
15 Overt Act No. 7: On or about February 12, 2019, defendant
16 ABBAS sent UICC 1 an electronic message containing a photograph
17 showing a computer screen displaying the website of a Romanian bank,
18 which picture contained account numbers -- including IBANs -- and
19 account balances for the Romanian bank account.
20 Overt Act No. 8: On or about February 13, 2019, defendant
21 ABBAS sent UICC 1 an electronic message containing a screenshot
22 displaying the website of a Romanian bank, which picture contained
23 account numbers -- including IBANs -- and account balances for the
24 Romanian bank account.
25 Overt Act No. 9: On or about March 10, 2019, in response to
26 messages from UICC 1 requesting a bank account in Dubai for “5m” and
27 stating “Brother I need it now or we will lose our chance pls,”
28 defendant ABBAS, through an electronic message, provided account
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1 information for a bank account in Dubai, including an account number
2 and IBAN.
3 Overt Act No. 10: On or about May 8, 2019, in response to
4 requests from UICC 1 for a bank account that could be used in a

5 scheme to “swap” the account on file and that the account be able to
6 “handle millions and not block,” defendant ABBAS sent UICC 1 an
7 electronic message containing the account information for a bank
8 account in Mexico, including the account number and IBAN.
9 Overt Act No. 11: On or about May 13, 2019, after UICC 1 told
10 defendant ABBAS that the bank account in Mexico would be used to
11 receive ǧ100 million from the Victim English Premier League Club and
12 ǧPLOOLRQIURPWKH9LFWLP8.&RPSDQ\DQGUHTXHVWHGDQRWKHUEDQN
13 account that could be used to receive fraudulent wire transfers,
14 defendant ABBAS sent UICC 1 electronic messages stating, in part in
15 coded language, that defendant ABBAS could not simply “keep
16 collecting” bank accounts from other coconspirators and “keep asking
17 for more,” and further stating that the bank accounts “cost a lot of
18 money now to open.”
19 Overt Act No. 12: On or about May 13, 2019, after UICC 1 told
20 defendant ABBAS about the Victim English Premier League Club and the
21 Victim U.K. Company, and also stated that UICC 1 had “10 more to do”
22 and thus was “putting 2 contracts on each acc,” defendant ABBAS
23 agreed, through an electronic message, to provide additional bank
24 accounts if the fraudulent transfers from the Victim English Premier
25 League Club and the Victim U.K. Company were successful.
26 Overt Act No. 13: On or about October 15, 2019, defendant
27 ABBAS or a coconspirator fraudulently induced the Victim Law Firm to
28 wire transfer approximately $922,857.76, from its account at Quontic
8
1 Bank, held in the State of New York, to the Chase Account, which was
2 opened in the name of a person other than ABBAS or UICC 1.
3 Overt Act No. 14: On or about October 17, 2019, defendant
4 ABBAS sent UICC 1, through an electronic message, a photograph of a

5 wire transfer confirmation relating to a wire transfer of
6 approximately $396,050 from the Chase Account to the CIBC Account,
7 which was opened in the name of UICC 2.
8 Overt Act No. 15: On or about October 17, 2019, while UICC 2
9 was within the Central District of California, UICC 1 informed UICC
10 2, through an electronic message, to look for a wire transfer of
11 approximately $396,050 to the CIBC Account.
12 Overt Act No. 16: On or about October 17, 2019, while within
13 the Central District of California, UICC 2 informed UICC 1, through
14 an electronic message, that the sum of approximately $396,050 had
15 been credited to the CIBC Account.
16 Overt Act No. 17: On or about October 17, 2019, UICC 1 told
17 defendant ABBAS, through an electronic message, that the wire
18 transfer of approximately $396,050 from the Chase Account to the CIBC
19 Account had been completed.
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1 COUNT TWO
2 [18 U.S.C. § 1956(h)]
5 Information.
6 A. OBJECTS OF THE CONSPIRACY
7 15. Beginning on an unknown date, no later than on or about

8 January 16, 2019, and continuing until on or about October 17, 2019,
9 in Los Angeles County, within the Central District of California, and
10 elsewhere, defendant ABBAS, and unindicted coconspirator #1 (“UICC
11 1”) and unindicted coconspirator #2 (“UICC 2”), together with others
12 known and unknown to the United States Attorney, knowingly conspired:
13 a. to conduct and attempt to conduct financial
14 transactions, affecting interstate and foreign commerce, knowing that
15 the property involved in the financial transactions represented the
16 proceeds of some form of unlawful activity, which, in fact, involved
17 the proceeds of specified unlawful activity -- namely, wire fraud, in
18 violation of Title 18, United States Code, Section 1343 -- and
19 knowing that the transactions were designed in whole and in part to
20 conceal and disguise the nature, location, source, ownership, and
21 control of the proceeds, in violation of Title 18, United States
22 Code, Section 1956(a)(1)(B)(i);
23 b. to transport, transmit, and transfer, and attempt to
24 transport, transmit, and transfer, funds from a place in the United
25 States to a place outside of the United States, knowing that the
26 property involved in the financial transactions represented the
27 proceeds of some form of unlawful activity, and which property was,
28 in fact, the proceeds of specified unlawful activity -- namely, wire
10
1 fraud, in violation of Title 18, United States Code, Section 1343 --
2 and knowing that the transportation, transmittal, and transfer were
3 designed in whole and in part to conceal and disguise the nature,
4 location, source, ownership, and control of the proceeds, in
5 violation of Title 18, United States Code, Section 1956(a)(2)(B)(i);
6 and
7 c. to engage and attempt to engage in monetary
8 transactions involving criminally derived property of a value greater
9 than $10,000, affecting interstate and foreign commerce, which was
10 derived from specified unlawful activity -- namely, wire fraud, in
11 violation of Title 18, United States Code, Section 1343 -- and
12 knowing that the funds represented the proceeds of some form of
13 unlawful activity, in violation of Title 18, United States Code,
14 Section 1957.
15 B. THE MANNER AND MEANS OF THE CONSPIRACY
16 16. The objects of the conspiracy were to be accomplished, in

17 substance, as follows:
18 a. The United States Attorney re-alleges and incorporates
19 here paragraphs 12.a through 12.e of Section B of Count One of this
20 Information.
21 C. OVERT ACTS
22 17. In furtherance of the conspiracy, and to accomplish its
23 objects, defendant ABBAS, and UICC 1 and UICC 2, together with others
24 known and unknown to the United States Attorney, on or about the
25 dates set forth below, committed and caused to be committed various
26 overt acts, in the Central District of California and elsewhere,
27 including, but not limited to, the following:
28 //
11
1 Overt Act Nos. 1–17: The United States Attorney re-alleges and
2 incorporates here Overt Act Number 1 through Overt Act Number 17 of
3 Section C of Count One of this Information.
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1 COUNT THREE
2 [18 U.S.C. §§ 1956(a)(2)(B)(i); 2(a)]
5 Information.
6 19. On or about October 17, 2019, in Los Angeles County, within
7 the Central District of California, and elsewhere, defendant ABBAS,
8 together with unindicted coconspirator #1 and unindicted
9 coconspirator #2, and others known and unknown to the United States
10 Attorney, each aiding and abetting the other, transported,
11 transmitted, and transferred, and attempted to transport, transmit,
12 and transfer, money from a place in the United States to and through
13 a place outside the United States -- namely, a wire transfer of
14 approximately $396,050 from the Chase Account to the CIBC Account --
15 knowing that the property involved represented the proceeds of some
16 form of unlawful activity, and which transactions, in fact, involved
17 the proceeds of specified unlawful activity, namely, wire fraud, in
18 violation of Title 18, United States Code, Section 1343, and knowing
19 that the transportation, transmission, and transfer was designed in
20 whole and in part to conceal and disguise the nature, location,
21 source, ownership, and control of such proceeds.
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1 COUNT FOUR
2 [18 U.S.C. §§ 1957; 2(a)]
5 Information.
6 21. On or about October 17, 2019, in Los Angeles County, within
7 the Central District of California, and elsewhere, defendant ABBAS,
8 together with unindicted coconspirator #1 and unindicted
9 coconspirator #2, and others known and unknown to the United States
10 Attorney, each aiding and abetting the other, knowingly engaged in,
11 attempted to engage in, and caused others to engage in and attempt to
12 engage in a wire transfer of approximately $396,050 from the Chase
13 Account to the CIBC Account, in and affecting interstate and foreign
14 commerce, in criminally derived property of a value greater than
15 $10,000, such property having been derived from specified unlawful
16 activity, namely, wire fraud, in violation of Title 18, United States
17 Code, Section 1343, knowing that the funds involved represented the
18 proceeds of some form of unlawful activity.
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1 FORFEITURE ALLEGATION ONE
2 [18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]
3 1. Pursuant to Rule 32.2 of the Federal Rules of Criminal
4 Procedure, notice is hereby given that the United States of America
5 will seek forfeiture as part of any sentence, pursuant to Title 18,
6 United States Code, Section 981(a)(1)(C) and Title 28, United States
7 Code, Section 2461(c), in the event of the defendant’s conviction of
8 the offense set forth in Count One of this Information.
9 2. The defendant, if so convicted, shall forfeit to the United
10 States of America the following:
11 (a) all right, title, and interest in any and all
12 property, real or personal, constituting, or derived from, any
13 proceeds traceable to the offenses; and
14 (b) To the extent such property is not available for
15 forfeiture, a sum of money equal to the total value of the property
16 described in subparagraph (a).
17 3. Pursuant to Title 21, United States Code, Section 853(p),
18 as incorporated by Title 28, United States Code, Section 2461(c), the
19 defendant, if so convicted, shall forfeit substitute property, up to
20 the value of the property described in the preceding paragraph if, as
21 the result of any act or omission of the defendant, the property
22 described in the preceding paragraph or any portion thereof
23 (a) cannot be located upon the exercise of due diligence; (b) has
24 been transferred, sold to, or deposited with a third party; (c) has
25 been placed beyond the jurisdiction of the court; (d) has been
26 substantially diminished in value; or (e) has been commingled with
27 other property that cannot be divided without difficulty.
28
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1 FORFEITURE ALLEGATION TWO
2 [18 U.S.C. § 982 and 28 U.S.C. § 2461(c)]
3 1. Pursuant to Rule 32.2(a) of the Federal Rules of Criminal
4 Procedure, notice is hereby given that the United States will seek
5 forfeiture as part of any sentence, pursuant to Title 18, United
6 States Code, Section 982(a)(1) and Title 28, United States Code,
7 Section 2461(c), in the event of the defendant’s conviction of the
8 offenses set forth in any of Counts Two through Four of this
9 Information.
10 2. The defendant, if so convicted, shall forfeit to the United
11 States of America the following:
12 (a) Any property, real or personal, involved in such
13 offense, and any property traceable to such property; and
14 (b) To the extent such property is not available for
15 forfeiture, a sum of money equal to the total value of the property
16 described in subparagraph (a).
17 3. Pursuant to Title 21, United States Code, Section 853(p),
18 as incorporated by Title 18, United States Code, Section 982(b)(1),
19 and Title 18, United States Code, Section 982(b)(2), the defendant,
20 if so convicted, shall forfeit substitute property, if, by any act or
21 omission of the defendant, the property described in the preceding
22 paragraph, or any portion thereof: (a) cannot be located upon the
23 exercise of due diligence; (b) has been transferred, sold to, or
24 deposited with a third party; (c) has been placed beyond the
25 jurisdiction of the court; (d) has been substantially diminished in
26 value; or (e) has been commingled with other property that cannot be
27 divided without difficulty. Substitution of assets shall not be
28 ordered, however, where the convicted defendant acted merely as an
16
1 intermediary who handled but did not retain the property in the
2 course of the money laundering offense unless the defendant, in
3 committing the offense or offenses giving rise to the forfeiture,
4 conducted three or more separate transactions involving a total of
5 $100,000.00 or more in any twelve-month period.
7 NICOLA T. HANNA
United States Attorney
8
10 CHRISTOPHER D. GRIGG
Assistant United States Attorney
11 Chief, National Security Division
12 CAMERON L. SCHROEDER
13 Chief, Cyber & Intellectual Property
Crimes Section
14
ANIL J. ANTONY
15 Assistant United States Attorney
Deputy Chief, Cyber & Intellectual
16 Property Crimes Section
17 JOSEPH B. WOODRING
18 Cyber & Intellectual Property Crimes
Section
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Case 2:20-cr-00322-ODW Document 11 Filed 07/29/20 Page 1 of 17 Page ID #:61

8 UNITED STATES DISTRICT COURT

9 FOR THE CENTRAL DISTRICT OF CALIFORNIA

20 The United States Attorney charges:

2 2. The “Chase Account” was a bank account held at JP Morgan

4 which was held in Pearland, Texas.

5 3. The “CIBC Account” was a bank account held at Canadian

6 Imperial Bank of Commerce, with the account number ending in 1716,

7 which was held in Ontario, Canada.

1 through the Society for Worldwide Interbank Financial

2 Telecommunication (“SWIFT”) communication system from the victim

3 bank’s computer system, authorizing and causing fraudulent wire

4 transfers to bank accounts used and controlled by conspirators.

2 [18 U.S.C. § 1349]

3 10. The United States Attorney re-alleges and incorporates here

4 paragraphs 1 through 9 of the Introductory Allegations of this

6 A. OBJECT OF THE CONSPIRACY

7 11. Beginning on an unknown date, but no later than on or about

2 international bank account number (“IBAN”). The bank account would

3 be opened in the name of a coconspirator or other person, to hide the

4 fraudulent nature of the deposit, wire, or transfer, and to conceal

5 and disguise the nature, location, source, ownership, and control of

6 the proceeds, but would be used or controlled, directly or

7 indirectly, by defendant ABBAS or UICC 1.

8 c. Defendant ABBAS and UICC 1, or their coconspirators,

9 would, through false or fraudulent pretenses, representations, and

10 promises, and concealment of material facts, cause a victim to

13 i. In a BEC fraud scheme, a coconspirator would

14 communicate with the victim-company -- fraudulently pretending to be

15 a company doing business with the victim-company -- and would provide

16 the victim-company with instructions to wire transfer a payment to

17 the bank account(s) identified to receive fraudulently obtained

19 ii. In a cyber-heist scheme, a coconspirator would

20 fraudulently send a message through the SWIFT system of the victim-

21 bank, directing a wire transfer from the victim-bank to the bank

22 account(s) identified to receive fraudulently obtained funds.

23 d. Defendant ABBAS and UICC 1, or their coconspirators,

25 and would further launder the funds through wire transfer(s) to

26 additional bank accounts in the names of persons other than defendant

28 assistance of additional coconspirators, such as UICC 2 -- so as to

1 obtain the money and so as to conceal and disguise the nature,

2 location, source, ownership, and control of the proceeds.

3 e. Defendant ABBAS and UICC 1 attempted to fraudulently

4 obtain and launder hundreds of millions of dollars in this manner.

6 13. In furtherance of the conspiracy, and to accomplish its

2 electronic message, provided the account information for a bank

3 account in Bulgaria, including the IBANs.

4 Overt Act No. 5: On or about February 12, 2019, after UICC 1

1 information for a bank account in Dubai, including an account number

3 Overt Act No. 10: On or about May 8, 2019, in response to

4 requests from UICC 1 for a bank account that could be used in a

2 opened in the name of a person other than ABBAS or UICC 1.

3 Overt Act No. 14: On or about October 17, 2019, defendant

4 ABBAS sent UICC 1, through an electronic message, a photograph of a

2 [18 U.S.C. § 1956(h)]

3 14. The United States Attorney re-alleges and incorporates here

4 paragraphs 1 through 9 of the Introductory Allegations of this

6 A. OBJECTS OF THE CONSPIRACY

7 15. Beginning on an unknown date, no later than on or about