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Case 3:19-cr-00141-SI Document 1 Filed 04/18/19 Page 1 of 9

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

UNITED STATES OF AMERICA 3:19-cr- (90} l/ 1-;-rz-


v. INDICTMENT

ONWUEMERIE OGOR GIFT aka 18 u.s.c. § 1349;


ONWUEMERIE OGOR; and 18 u.s.c. § 1343;
KELVIN USIFOH, 18 U.S.C. § 1956(h)

Defendants. Forfeiture Allegations

THE GRAND JURY CHARGES:

INTRODUCTORY ALLEGATIONS:

1. Defendant ONWUEMERIE OGOR GIFT aka ONWUEMERIE OGOR

(hereinafter "OGOR") is a citizen of the country of Nigeria but may reside elsewhere. OGOR

uses aliases to conceal his identity and used aliases when communicating with victims.

2. Defendant KELVIN USIFOH (hereinafter "USIFOH") is a citizen of the

country of Nigeria but may reside elsewhere. USIFOH uses aliases to conceal his identity and

used aliases when communicating with victims.

3. ADULT VICTIM 1 (hereinafter "AVl ") resides in the District of Oregon.

4. ADULT VICTIM 2 (hereinafter "AV2") and ADULT VICTIM 3 (hereinafter

"AV3 ") reside in the State of California.

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5. Bitcoin is a type of virtual currency. Its value, relative to fiat currency like the

United States Dollar, fluctuates over time. For example, bitcoin traded for approximately

$10,326.50 on February 26, 2018, and for approximately $6,714.82 on June 18, 2018.

6. Coinbase is a platform used to buy and sell virtual currency, such as bitcoin.

Coinbase is based in San Francisco, California. Coinbase provides a service for customers to

create web-based "wallets" to store virtual currencies, like bitcoin, ethereum, and litecoin, and to

make transactions with virtual currency, including the purchase and sale of virtual currency with

traditional fiat currency. Typically, customers of Coinbase initiate transfers of bitcoin by using

Coinbase's website. Other companies offer similar services including Gemini Trust Company,

LLC ("Gemini"), based in New York City, New York, and LocalBitcoins.com, based in

Helsinki, Finland.

7. Bitcoin and other virtual currencies can also be held in wallets that are not web-

based, such as a desktop wallet where access to the virtual currency is stored locally on a

computer. While companies like Coinbase, Gemini, and LocalBitcoins.com maintain information

about who owns an account with their service, an owner of a desktop wallet or other private

wallet is generally anonymous.

COUNTl
(Conspiracy to Commit Wire Fraud)
(18 u.s.c. § 1349)

8. Beginning on or about March 3, 2017, and continuing until on or about December

31 , 2018, within the District of Oregon and elsewhere, defendap.ts OGOR and USIFOH and

others, known and unknown to the Grand Jury, did knowingly combine, conspire, confederate,

and agree with each other to commit wire fraud, to wit, they agreed to knowingly devise a

scheme and artifice to defraud as to material matters and to obtain money and property by means

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of false and fraudulent pretenses, representations, promises, and omissions in violation of 18

U.S.C. § 1343 .

MANNER AND MEANS AND SCHEME TO DEFRAUD

9. Defendants and others used the following manner and means to carry out the

conspiracy and scheme to defraud:

10. It was part of the conspiracy and scheme to defraud that defendants and their co-

conspirators purchased the domain name "wealthcurrency.com" through Namecheap, a company

based in Los Angeles, California, that provides domain names and other services. Defendants

and their co-conspirators also purchased "WhoisGuard," a service described by the provider as

"a privacy protection service that prevents people from seeing your name, address, phone

number and email when they do a Whois search on your domain." The user information on the

website lists an address in Indonesia but the login IP addresses are primarily from Nigeria. They

used USIFOH's credit card to pay for some of the services with Namecheap.

11. It was part of the conspiracy and scheme to defraud that defendants and their co-

conspirators uploaded publicly accessible webpages at "www.wealthcurrency.com" that

promised investors a 20-50 percent return on investments with bitcoin through their entity and

promised "zero risk" and instant withdrawals. Defendants and their co-conspirators encouraged

victims to transfer bitcoins to specific addresses and made false promises about the use of

victims' bitcoins including promising that the bitcoins would be invested with "unique trading

methods" that would "maintain a constant high interest rate."

12. It was part of the conspiracy and scheme to defraud that defendants and their co-

conspirators used the alias "Theo Laurence" to send emails to victims to encourage victims to

send bitcoins as part of the investment scam.

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13. It was part of the conspiracy and scheme to defraud that defendants and their co-

conspirators created the false persona of "Fred Anthony" by creating an online profile that used

photos of a real person, ADULT VICTIM 4 (hereinafter "AV4"), and by sending emails on

behalf of "Fred Anthony" to encourage victims to send bitcoins as part of the investment scam.

14. It was part of the conspiracy and scheme to defraud that defendants and their co-

conspirators told victims to deposit more bitcoins in order to receive the proceeds of their

"investments." Defendants and their co-conspirators never returned any of the money that the

victims invested.

15. It was part of the conspiracy and scheme to defraud that defendants and their co-

conspirators told victims to deposit bitcoins into a private wallet address beginning " 19Etto" for

investment purposes. In reality, defendants and their co-conspirators then transferred bitcoin

from " 19Etto" to other accounts they controlled and eventually exchanged the bitcoin for fiat

currency, specifically Nigerian Naira.

16. It was part of the conspiracy and scheme to defraud that defendants and their co-

conspirators purchased the domain name "boomcurrency.com" on or about April 2, 2018, about

a year after the scheme began, and perpetuated the same scheme to convince victims to send

bitcoin to wallet addresses, including the " 19Etto" address. On the same day, they also purchased

other domain names including the domain "merrycurrency.com."

17. Through the conspiracy, defendants and their co-conspirators agreed to and did

cause the transmission of wires that traveled interstate and internationally including the use of

emails, text messages, transfers of money over wire, transfers of bitcoin over wire, and use of the

internet such as the fraudulent websites noted above as well as legitimate websites like Coinbase.

All in violation of 18 U.S.C. § 1349.

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COUNTS 2-12
(Wire Fraud)
(18 u.s.c. § 1343)

1. The Introductory Allegations, Count 1, and all prior paragraphs of this Indictment

are incorporated herein.

2. On or about the dates set forth in each Count below, in the District of Oregon and

elsewhere, defendants OGOR and USIFOH, together with others known and unknown to the

Grand Jury, for the purposes of attempting to execute and executing the material scheme to

defraud, and to obtain money and property by means of materially false and fraudulent pretenses,

representations, promises, and omissions, as described in Count 1, knowingly transmitted, or

caused to be transmitted, by means of wire and radio communications in interstate or foreign

commerce:

Count Date Description of Execution


2 March 13, 2017 Registration of the of domain "wealthcurrency.com."
3 December 30, 2017 An email sent to A V2 from Theolaurence27@gmail.com
promising profits, stating in part: "I can show you a reliable
way .to trade 0.5Btx and make 3-4Btc after 7 days ."
4 January 3, 2018 AV2's transfer of approximately 0.5 bitcoin from his Gemini
account to wallet address beginning " 19Etto."
5 February 22, 2018 A text message sent to A Vl saying in part: "Don' t be scared,
my platform works 99%. You won' t lose anything."
6 February 22, 2018 A text message sent to AVl saying in part: "The platform we
are going to use will give you 30% of what you put weekly . ...
You will earn more by trading. "
7 February 24, 2018 A text message sent to A Vl containing a picture AV 4 with his
family.
8 February 26, 2018 A Vl ' s transfer of approximately 0.28 bitcoin from his Coinbase
wallet address beginning " 19Etto."
9 March 7, 2018 A text message sent to AVl telling AVl to "add .2Btc so you
can withdraw successfully."
10 April 2, 2018 Registration of the domain "boomcurrency .com."
11 June 11 , 2018 A V3 's transfer of approximately 8 bitcoin from his Coinbase
wallet to wallet address beginning " 19Etto."
12 June 18, 2018 A V3 ' s transfer of approximately 2.1 bitcoin from his Coinbase
wallet to wallet address beginning " 19Etto. "
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All in violation of Title 18, United States Code, Section 1343.

COUNT 13
(Conspiracy to Commit the Laundering of Monetary Instruments)
(1 8 U.S.C. § 1956(h))

1. The Introductory Allegations, Counts 1 through 12, and all prior paragraphs of

this Indictment are incorporated herein.

2. Beginning on an unknown date but no later than in or about March 2017, and

continuing until at least on or about March 8, 2019, within the District of Oregon and elsewhere,

defendants OGOR and USIFOH, and others, known and unknown to the Grand Jury, did

knowingly combine, conspire, and agree to commit offenses against the United States in

violation of 18 U.S.C. § 1956, to wit: they did knowingly conduct and attempt to conduct

financial transactions affecting interstate and foreign commerce, which involved the proceeds of

a specified unlawful activity, that is Wire Fraud, knowing that the transactions were designed in

whole and in part to conceal and disguise the nature, location, source, ownership, and control of

the proceeds of specified unlawful activity, and that while conducting and attempting to conduct

such financial transactions knew that the property involved in the financial transactions

represented the proceeds of some form of unlawful activity in violation of 18 U.S .C. §

1956(a)(l )(B)(i).

MANNER AND MEANS OF THE CONSPIRACY

3. Defendants and others used the following manner and means, among others, to

accomplish the objectives of the conspiracy:

4. It was part of the conspiracy to conceal the nature, location, source, ownership,

and control of proceeds of fraud by using private virtual currency wallets to receive and to

transfer bitcoin in an effort to conceal the disposition of those proceeds.


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5. It was part of the conspiracy that defendants and their co-conspirators agreed to

commit Wire Fraud and did commit Wire Fraud as alleged in Counts 1-12.

6. It was part of the conspiracy that OGOR, USIFOH, and others, known and

unknown to the Grand Jury, agreed to and did engage in financial transactions with the proceeds

of the bitcoin investment scam. Defendants and their co-conspirators transferred bitcoins to and

from private wallets that were not associated with a web-based company that store information

on account holders. Defendants and their co-conspirators often transferred proceeds through

multiple private wallets before eventually converting the proceeds to fiat currency, mainly

Nigerian Naira.

7. As an example, it was part of the conspiracy that the defendants and others,

known and unknown to the Grand Jury created proceeds by inducing AV3 to transfer

approximately 8.00 bitcoin to the wallet address "19Etto" on or about June 11 , 2018 . Defendants

and their co-conspirators then engaged in financial transactions that affected interstate commerce

with those proceeds. On or about June 11 , 2018, defendants and their co-conspirators transferred

or caused to be transferred approximately 4.00 bitcoin out of the private wallet address "19Etto"

to another private wallet address beginning " 1Cn88K." Also, on or about June 11 , 20 18,

defendants and their co-conspirators transferred or caused to be transferred approximately 3 .99

bitcoin out of the private wallet address " 1Cn88K" to a Localbitcoins.com wallet owned by

OGOR.

8. It was part of the conspiracy that defendants and others, known and unknown to

the Grand Jury created proceeds by inducing A V3 to transfer 2.1 bitcoin to the wallet address

" 19Etto" on or about June 18, 2018. Defendants and their co-conspirators then engaged in

financial transactions that affected interstate commerce with those proceeds. On or about June

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20, 2018, defendants and their co-conspirators transferred or caused to be transferred

approximately 4.95 bitcoin out of the private walled address "19Etto" to a Localbitcoins.com

wallet owned by OGOR, and that transfer included the 2.1 bitcoin from AV3.

9. During the scheme, defendants and their co-conspirators exchanged over 50

bitcoin for Nigerian Naira.

All in violation of 18 U.S.C. § 1956(h).

FIRST FORFEITURE ALLEGATION

Upon conviction of the offense alleged in Counts 1 through 12 of this Indictment,

defendants OGOR and USIFOH shall forfeit to the United States pursuant to 18 U.S.C.

§ 982(a)(l)(C), any property constituting, and derived from, proceeds defendants obtained

directly and indirectly, as the result of such violation.

SECOND FORFEITURE ALLEGATION

Upon conviction of the offense alleged in Count 13 of this Indictment, defendants

OGOR and USIFOH shall forfeit to the United States pursuant to 18 U.S.C. § 982(a)(l), all

property, real or personal, involved in the money laundering offense and all property traceable to

such property, including but not limited to a money judgment for a sum of money equal to the

amount of property involved in the money laundering conspiracy as alleged in Count 13.

SUBSTITUTE ASSETS

If any of the above-described forfeitable property listed in Counts 1 through 13 of this

Indictment, as a result of any act or omission of the defendants:

(a) cannot be located upon the exercise of due diligence;

(b) has been transferred or sold to, or deposited with, a third party;

(c) has been placed beyond the jurisdiction of the court;

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(d) has been substantially diminished in value; or

(e) has been c·ornrningled with other property which cannot be divided without difficulty;

it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) as incorporated by 18 U.S.C.

§ 982(b ), to seek forfeiture of any other property of said defendants up to the value of the

forfeitable property described in these forfeiture allegations.

Dated this April ~ 2019. A TRUE BILL.

Presented by:

BILLY J. WILLIAMS

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QUINN P. HARRINGTON, OSB #083544


Assistant United States Attorney

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