Вы находитесь на странице: 1из 3

Page 1 of3

CRIMINAL COURT OF THE CITY OF NEW YORK.


COUNTY OF NEW YORK
THE PEOPLE OF THE STATE OF NEW YORK
MISDEMEANOR

-against1. BITCOINHYIP.ORG,
2. YOUYOU FINANCE,

ADA Cory Jacobs


Defendants.

Senior Investigator Gregory Dunlavey, Shield 153 of the N.Y. .County DA's
Office Investigation Bureau, states as follows:

The defendants are charged with:


1 GBL 352-c(1)(a)

2 PL 190.60(1)

3 PL 155.25

Securities Fraud-Not DNA Eligible


(defendant #1: 1 count)
(defendant #2: 1 count)
Scheme to Defraud in the Second Degree
(defendant #1: 1 count)
(defendant #2: 1 count)
Petit Larceny
(defendant #1: 1 count)
(defendant #2: 1 count)

At the times and places described below in the County and State of New York
and elsewhere, the defendants, and an agent and employee of the defendants, used and
employed fraud, deception, conceahnent, suppression, false pretense and fictitious and
pretended purchase and sale, and the defendants engaged in such conduct to induce and
promote the issuance, distribution, exchange, sale, negotiation and purchase within and from
this state of securities and commodities; the defendants engaged in a scheme constituting a
systematic ongoing course of conduct with intent to defraud more than one person and to
obtain property from more than one person by false and fraudulent pretences,
representations and promises and so obtained property from one and more of such persons;
the defendants stole property.

The factual basis for these charges are as follows:


In or about July 2014, I began investigating certain groups; these particular groups
used websites pitching unrealistic investment schemes using a virtual currency known as
Bitcoin. Bitcoin is a payment system used for transferring value electronically from one
person to an.o ther person through a software "bit wallet." The wallet contains computergenerated bitaddresses representing-a quantity of bitcoins held by a person. By seeking
investors willing to invest bitcoins in exchange for the promise of a return, these websites

Page 2 of 3

CRIMINAL COURT OF THE CITY OF NEW YORK


COUNTY OF NEW YORK
THE PEOPLE OF THE STATE OF NEW YORI<
MISDEMEANOR

-against1. BITCOINHYIP.ORG,
2. YOUYOU FINANCE,

ADA Cory Jacobs


Defendants.

were using bitcoins as a security. Notably, the Bitcoin payment system is unregulated.
Additionally, once a person transmits bitcoins to another person, there is no way to recall or
reverse the payment.
On July 29, 2014, using an undercover identity, I emailed the contact email
address for one such group ("admin@bitcoinhyip.org"), which advertised itself as defendant
BITCOINHYIP.ORG and used a website of the same name, BITCOINHYIP.ORG. I am
informed by a representative of the registrar company where BITCOINHYIP.ORG's
website registration was processed that BITCOINHYIP.ORG and over 70 other websites
were registered by the same company, defendant YOUYOU FINANCE. I and members of
the District Attorney's Office have reviewed those websites. Those websites offered similar
investments as defendant BITCOINHYIP.ORG.
Defendant BITCOINHYIP.ORG represented both in its communications with
me and on its website that it "was [b]acked by a REAL company" and had a "long history."
I was promised a return of three times my investment within 48 hours; i n other words, if I
transmitted one bitcoin to a bitaddress set forth by the website, I would be transmitted, in
return, three bitcoins to my bitaddress from defendant BITCOINHYIP.ORG within 48
hours. It was further represented that I would receive my investment return "instantly,'' that
I could not lose money in the investment, and that the funds were "managed by a team of
BitcoinHyip.org HYIP investment experts." These representations, which were proffered by
defendants BITCOINHYIP.ORG and YOUYOU FINANCE, were pitched to anyone
accessing the defendant BITCOINHYIP.ORG website. Similar representations were made
to people at the other websites registered by YOUYOU FINANCE.
On August 11, 2014, following a series of email communications in which I was
reassured of the truth of the representations--that I would receive ~three . bitcoins for one
bitcoin within 48 hours--I sent one bitcoin to defendants BITCOINHYIP.ORG and
YOUYOU FINANCE at the bitaddress provided for transferring one bitcoin on the
BITCOINHYIP.ORG website. I subsequently received an email from the said defendants
con.firming that my transfer of one bitcoin had been received. On August 11, 2014, the
value of a bitcoin fluctuated on the marketplace between $566.60 and $586.10 USD.
Thereafter, defendants BITCOINHYIP.ORG and YOUYOU FINANCE failed

Page 3 of 3

CRIMINAL COURT OF THE CITY OF NEW YORI<.:


COUNTY OF NEW YORI<.:
THE PEOPLE OF THE STATE OF NEW YORK
MISDEMEANOR

-against1. BITCOINHYIP.ORG,

ADA Cory Jacobs

2. YOUYOU FINANCE,
Defendants.

to and refused to transmit the promised investment return of three bitcoins, instantly or
otherwise, or to return the bitcoin that I originally transmitted to them. That refusal has
continued to the present.
I am also aware of the identity of at least one other investor, whose identity is
known to the New York County District Attorney's Office. This individual stated that he,
too, invested a bitcoin with defendants BITCOINHYIP.ORG and YOUYOU FINANCE
only to be refused his promised investment or the return of his original bitcoin.
Additionally, I viewed an online public database showing transfers of bitcoins.
The database does not identify people, but it does identify the amounts, the time and date,
and the computer-generated bitaddresses related to the transfers. From reviewing this
database, I am aware that many other bitcoins have been transmitted to the bitaddresses
given by defendants BITCOINHYIP.ORG and YOUYOU FINANCE for investments, and
that no bitcoins have been returned to the originating bitaddresses. Thus, it is reasonable to
infer that no individual who sent bitcoins to defendants BITCOINHYIP.ORG and
YOUYOU FINANCE received the promised return.
As part of this investigation, on or about January 16, 2015, a search warrant was
issued and the domain names of 72 websites used in the above-described securities fraud,
scheme to defraud, and larceny, all of which were registered by defendant YOUYOU
FINANCE, were seized.

False statements made in this written instrument are punishable as a class A


misdemeanor pursuant to section 210.45 of the Penal Law, and as other crimes.

l 'too t-rS
Date

Time