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Case 1:16-cr-00026-RJA-MJR Document 8 Filed 03/09/16 Page 1 of 6

IN THE DISTRICT COURT OF THE UNITED STATES


for the Western District of New York
____________________
NOVEMBER 2014 GRAND JURY
(Impaneled 11/07/2014)

THE UNITED STATES OF AMERICA

INDICTMENT

-vsViolations:
Title 18, United States Code, Sections
1956(a)(1)(A)(i), 1956(h), 1957(a) and 2;
Title 21, United States Code, Section
846
(4 Counts and 2 Forfeiture Allegations)

ZHE WANG
(Counts 1-4), and
KEVIN SZURA
(Counts 1-4)
COUNT 1

(Conspiracy to Distribute Controlled Substances)


The Grand Jury Charges That:
Beginning in or before March 2015, the exact date being unknown to the Grand
Jury, and continuing until on or about March 7, 2016, in the Western District of New York,
and elsewhere, the defendants, ZHE WANG and KEVIN SZURA, did knowingly,
willfully, and unlawfully combine, conspire, and agree together and with others, known and
unknown to the Grand Jury, to commit the following offenses, that is, to possess with the
intent to distribute, and to distribute, Schedule I and II controlled substances, and
alprazolam, a Schedule IV controlled substance, in violation of Title 21, United States
Code, Sections 841(a)(1), 841(b)(1)(C), and 841(b)(2).
All in violation of Title 21, United States Code, Section 846.

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COUNT 2
(Money Laundering Conspiracy)
The Grand Jury Further Charges That:
Beginning in or before March 2015, the exact date being unknown to the Grand
Jury, and continuing until on or about March 7, 2016, in the Western District of New York,
and elsewhere, the defendants, ZHE WANG and KEVIN SZURA, did knowingly,
willfully, and unlawfully combine, conspire, and agree together and with others, known and
unknown to the Grand Jury, to commit the following offenses, that is:
a.

to knowingly conduct financial transactions affecting interstate and foreign

commerce, that is, the purchase, with United States currency, of bitcoins over and through
the use of the Internet, which involved the proceeds of specified unlawful activity, that is,
the unlawful distribution of controlled substances, and conspiracy to do so, in violation of
Title 21, United States Code, Sections 841(a)(1) and 846, with the intent to promote the
carrying on of such specified unlawful activity, and while knowing that the property
involved in the financial transactions, that is, the United States currency, represented the
proceeds of some form of unlawful activity, in violation of Title 18, United States Code,
Section 1956(a)(1)(A)(i); and
b.

to knowingly engage in a monetary transaction within the United States, that

is, the transfer and exchange of United States currency for bitcoins over and through the use
of the Internet, affecting interstate and foreign commerce, in criminally derived property of
a value greater than $10,000, such property, that is, the United States currency, having been
derived from specified unlawful activity, that is, the unlawful distribution of controlled

Case 1:16-cr-00026-RJA-MJR Document 8 Filed 03/09/16 Page 3 of 6

substances, and conspiracy to do so, in violation of Title 21, United States Code, Sections
841(a)(1) and 846; all in violation of Title 18, United States Code, Section 1957(a).
All in violation of Title 18, United States Code, Section 1956(h).

COUNT 3
(Money Laundering)
The Grand Jury Further Charges That:
On or about February 29, 2016, in the Western District of New York, the
defendants, ZHE WANG and KEVIN SZURA, did knowingly conduct, and attempt to
conduct, a financial transaction affecting interstate and foreign commerce, that is, the
purchase, with United States currency, of bitcoins over and through the use of the Internet,
which involved the proceeds of specified unlawful activity, that is, the unlawful distribution
of controlled substances, and conspiracy to do so, in violation of Title 21, United States
Code, Sections 841(a)(1) and 846, with the intent to promote the carrying on of such
specified unlawful activity, and while knowing that the property involved in the financial
transaction, that is, the United States currency, represented the proceeds of some form of
unlawful activity.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(A)(i) and 2.

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COUNT 4
(Monetary Transaction in Criminally Derived Property)
The Grand Jury Further Charges That:
On or about February 29, 2016, in the Western District of New York, the
defendants, ZHE WANG and KEVIN SZURA, did knowingly engage, and attempt to
engage, in a monetary transaction within the United States, that is, the transfer and
exchange of United States currency for bitcoins over and through the use of the Internet,
affecting interstate and foreign commerce, in criminally derived property of a value greater
than $10,000, such property, that is, the United States currency, having been derived from
specified unlawful activity, that is, the unlawful distribution of controlled substances, and
conspiracy to do so, in violation of Title 21, United States Code, Sections 841(a)(1) and 846.
All in violation of Title 18, United States Code, Sections 1957(a) and 2.

FIRST FORFEITURE ALLEGATION


(Drug Proceeds)
The Grand Jury Alleges That:
Upon conviction of the offense alleged in Count 1 of the Indictment, the defendants,
ZHE WANG and KEVIN SZURA, shall forfeit to the United States of America all of their
interest in any and all property, real or personal, constituting or derived from any proceeds
that they obtained, directly or indirectly, as the result of such violation, including, but not
limited to, the following property:

Case 1:16-cr-00026-RJA-MJR Document 8 Filed 03/09/16 Page 5 of 6

CURRENCY:
a.

The sum of eleven thousand eight hundred and thirty-four dollars


($11,834.00) in United States currency seized by federal law
enforcement officers from the defendant Zhe Wang on March 7, 2016;

b.

The sum of ten thousand eight hundred eighty-two dollars


($10,882.00) in United States currency seized by federal law
enforcement officers from the defendant Kevin Szura on March 7,
2016; and

c.

The sum of eight thousand four hundred and eighty dollars ($8,480.00)
in United States currency given to federal law enforcement officers by
the defendants in exchange for bitcoins on March 7, 2016.

MONETARY JUDGMENT:
a.

The sum of sixty-five thousand eight hundred and sixty dollars


($65,860.00) in United States currency, the value of bitcoins purchased
and received by the defendants, and if not readily available, to be
secured by a money judgment in said amount.

All pursuant to Title 21, United States Code, Sections 853(a)(1) and 853(a)(2).

SECOND FORFEITURE ALLEGATION


(Money Laundering)
The Grand Jury Further Alleges That:
Upon conviction of any of Counts 2, 3, and 4 of the Indictment, the defendants,
ZHE WANG and KEVIN SZURA, shall forfeit to the United States all property involved
in the offenses including, but not limited to, the following property:
CURRENCY:
a.

The sum of eight thousand four hundred and eighty dollars ($8,480.00)
in United States currency given to federal law enforcement officers by
the defendants in exchange for bitcoins on March 7, 2016.

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MONETARY JUDGMENT:
b.

The sum of sixty-five thousand eight hundred and sixty dollars


($65,860.00) in United States currency, the value of bitcoins purchased
and received by the defendants, and if not readily available, to be
secured by a money judgment in said amount.

All pursuant to Title 18, United States Code, Section 982(a)(1).

DATED: Buffalo, New York, March 9, 2016.

WILLIAM J. HOCHUL, JR.


United States Attorney
BY:

S/WEI XIANG
Assistant United States Attorney
United States Attorneys Office
Western District of New York
138 Delaware Avenue
Buffalo, New York 14202
716/843-5806
Wei.Xiang@usdoj.gov

A TRUE BILL:
S/FOREPERSON