ORIGINAL mor aay __1 2 MAG 003 0 Assistant United states Attorney Before: HONORABLE HENRY B. PITMAN United States Magistrate Judge Southern District of New York : COMPLAINT : Violation of we 18 U.S.C. §§ 1349, 1344 & 2 LAURENTIU IULIAN BULAT, : County of Offense: New York Defendant. SOUTHERN DISTRICT OF NEW YORK, ss. BRIC FRIEDMAN, being duly sworn, deposes and says that he is a Special Agent with the United states Secret Service, and charges as follows: COUNT_ONE (Conspiracy to Commit Bank Fraud) 1, From at least in or about May 2011, through on or about January 5, 2012, in the Southern District of New York and elsewhere, LAURENTIU IULIAN BULAT, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit bank fraud, in violation of Title 18, United states Code, Section 1344. 2, It was a part and an object of the conspiracy that LAURENTIU IULIAN BULAT, the defendant, and others known and unknowa, willfully and knowingly would and did execute and attempt to execute a scheme and artifice to defraud a financial institution, the deposits of which were then insured by the Federal Deposit Insurance Corporation, and to obtain moneys, funds, credits, assets, securities, and other property owned by, and under the custody and control of, such financial institution, by means of false and fraudulent pretenses, representations, and promises.OVERT ACT 3. | In furtherance of the conspiracy and to effect the illegal object thereof, LAURENTIU IULIAN BULAT, ‘the defendant, and others known and unknown, committed the following overt act, among others, in the Southern District of New York and elsewhere: a. On or about January 5, 2012, BULAT placed ATM skimming devices at two ATM machines at an HSBC Bank at 68” Street and 3" Avenue (the “HSBC Bank Branch") in New York, New York. (Title 18, United States Code, Section 1349.) COUNT THO (Bank Fraud) 4. From at least in or about May 2011 through on or about January 5, 2012, in the Southern District of New York and elsewhere, LAURENTIU IULIAN BULAT, the defendant, willfully and knowingly did execute and attempt to execute a scheme and artifice to defraud a financial institution, the deposits of which were then insured by the Federal Deposit Insurance Corporation, and to obtain moneys, funds, credits, assets, securities, and other property owned by, and under the custody and control of, such financial institution by means of false and fraudulent pretenses, representations, and promises, to wit, BULAT and others placed ATM skimming devices at ATM machines at HSBC banks in Manhattan, Long Island, Westchester, and thereafter used information stolen through the use of the ATM skimming devices to withdraw funds from accounts of HSBC customers. (Title 18, United States Code, Sections 1344 and 2.) The bases for deponent’s knowledge and the foregoing charges are, in part, as follows: 5. I ama Special Agent with the United states Secret Service, and I have been personally involved in the investigation of this matter. This affidavit is based in part surveillance by myself and others, upon my conversations with law-enforcement officers, investigators of HSBC, and others, and upon my examination of reports, records, and video images. Because this affidavit is being submitted for the limited purpose of establishing probable cause, it does not include all of the facts that I and other law enforcement agents have learned during the course of this investigation. Where the contents of documents and the actions, statements and conversations of others arereported herein, they are reported in substance and in part, except where otherwise indicated. Since February 2010, I have been a member of a squad that investigates criminal organizations that focus on defrauding financial institutions and their customers by placing devices at Automated Teller Machines ("ATMs"). Customers access their bank accounts through an ATM by means of a card issued by banks that has been encoded with the customer’s account information, in addition to a Personal Identification Number (*PIN’). Bank cards typically bear a magnetic stripe on which account-related information has been electronically coded. Banks place ATMs in vestibules that can be accessed by customers when the branches are otherwise closed by swiping a bank card into a card reader located at the entrance to the ATM vestibule. ‘skimming’ is an illegal activity that involves the installation of devices, usually undetectable by ATM users, that surreptitiously record the user’s bank account numbers, along with the corresponding PINs, enabling criminals to use that information to steal money from customers’ accounts, 7, Since in or about May 2011, I and other secret Service agents have been investigating a fraud ring that operates primarily at HSBC banks in the New York City metropolitan area. Members of the fraud ring obtain card numbers and corresponding PINs by using compromised card readers and "pin-hole" cameras. Specifically, the investigation has revealed, through both physical surveillance and reviews of bank video camera recordings, reviews of bank account records, discussions with HSBC representatives, and other law enforcement agents, among other ways, that: (a) Members of the fraud ring install fraudulent “skimming” devices on card readers in ATMs which record the information contained on the cards as they are inserted into the card readers, including account numbers; (b) Members of the fraud ring also install pin- hole cameras on ATM machines in order to record customers’ PINs as they are entered into the machines. The pin-hole cameras are typically not apparent to ATM users. As part of this investigation, I have retrieved such pin-hole camera devices that were unlawfully installed and have inspected them. The pin-hole camera equipment typically includes a small USB port with an sD card that stores video; (c) Members of the fraud ring retrieve the fraudulent pin-hole cameras and card readers (collectively, the