Page:Special counsel indictment of Netyksho et al.pdf/21

Count	Approximate Date	Victim	Means of Identification
2	March 21, 2016	Victim 3	Username and password for personal email account
3	March 25, 2016	Victim 1	Username and password for personal email account
4	April 12, 2016	Victim 4	Username and password for DCCC email account
5	April 15, 2016	Victim 5	Username and password for DCCC email account
6	April 18, 2016	Victim 6	Username and password for DCCC email account
7	May 10, 2016	Victim 7	Username and password for DNC email account
8	June 2, 2016	Victim 2	Username and password for personal email account
9	July 6, 2016	Victim 8	Username and password for personal email account

All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2.

COUNT TEN
(Conspiracy to Launder Money)

56. Paragraphs 1 through 19, 21 through 49, and 55 are re-alleged and incorporated by reference as if fully set forth herein.

57. To facilitate the purchase of infrastructure used in their hacking activity–including hacking into the computers of U.S. persons and entities involved in the 2016 U.S. presidential election and releasing the stolen documents–the Defendants conspired to launder the equivalent of more than $95,000 through a web of transactions structured to capitalize on the perceived anonymity of cryptocurrencies such as bitcoin.

58. Although the Conspirators caused transactions to be conducted in a variety of currencies, including U.S. dollars, they principally used bitcoin when purchasing servers, registering domains, and otherwise making payments in furtherance of hacking activity. Many of these payments were

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