Page:US District Court, Southern District of New York.-Liberty Reserve Indictment.pdf/1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA - v. - LIBERTY RESERVE S.A., ARTHUR BUDOVSKY, a/k/a "Arthur Belanchuk," a/k/a "Eric Paltz," VLADIMIR KATS a/k/a "Ragnar," AHMED YASSINE ABDELGHANI, a/k/a "Alex," ALLAN ESTEBAN HIDALGO JIMENEZ, a/k/a "Allan Garcia," AZZEDDINE EL AMINE, MARK MARMILEV, a/k/a "Marks, " a/k/a "Mark Halls," and MAXIM CHUKHAREV, Defendants.

SEALED INDICTMENT 13 cr. 13 CRIM 368

COUNT ONE

(Conspiracy to Commit Money Laundering)

The Grand Jury charges:

THE DEFENDANTS

1. Incorporated in Costa Rica in 2006, LIBERTY RESERVE S.A. ("LIBERTY RESERVE"), the defendant, has for years operated one of the world's most widely used digital currencies. Through its website, www.libertyreserve.com, LIBERTY RESERVE has provided its users with what it described as "instant, real-time currency for international commerce," which can be used to "send