Approved:  

DANIEL c. CHENBERG
Assistant United States Attorneys

Before: THE HONORABLE HENRY B. PITMAN
United States MagiStrate Judge
Southern District of New Yorm

    

 

m. .. m. m. 
UNITED STATES OF AMERICA SEALED COMPLAINT
v. Violations of
. 18 U.S.C. 371, 666,

JOHN W. ASHE, 1956, and 2; and
FRANCIS LORENZO, 26 U.S.C. 7206(1)
NG LAP SENG, 

a/k/a ?David Ng,? COUNTIES OF OFFENSE:
JEFF C. YIN, 

a/k/a ?Yin Chuan,? NEW YORK
SHIWEI YAN, WESTCHESTER

a/k/a ?Sheri Yan,? and -
HEIDI HONG PIAO,

a/k/a ?Heidi Park,?

Defendants.

.. .. h. m. .. 

DISTRICT OF NEW YORK, 33.:

JASON P. ALBERTS, being duly sworn, deposes and says that he
ijsa_Special Agent with the Federal Bureau.of Investigation 
and charges as follows:

I

COUNT ONE
(Conspiracy to Bribe a Snited Nations Official)

1. From at least in or about 2011, up to and including in or
about December 2014, in the Southern District of New York and
elsewhere, FRANCIS LORENZO, NG LAP SENG, a/k/a ?DaVid Ng,? JEFF C.
YIN, a/k/a ?Sheri?Yanq? and HEIDIIHONG
?Heidi Park,? the defendants, and others known and
unknown, willfully and knowingly did combine, conspire, confederate,
and agree together and with each other to violate Title 18, United
States Code, Section 666.

 

2. It was a part and an object of the conspiracy that FRANCIS
LORENZO, NG LAP SENS, a/k/a ?David Ng? JEFF C. YIN, a/k/a
?Yin Chuan, SHIWEI YAN, a/k/a ?Sheri Yan, and HEIDI HONG PIAO, a/k/a
?Heidi Park,? the defendants, and others known and unknown, would
and did corruptly give, offer, and agree to give a thing of value
to a person, with the intent to influence and reward an agent of an
'organizationq in.connectionvwh?ia.business, transaction? and.series
of transactions of such organization, involving'a thing of value of
$5,000 and.more, while such.organization was in receipt of, in.a one
year period, benefits in excess of $10,000 under a Federal program
involving a grant, contract, subsidy, loan, guarantee, insurance,
and other form of federal assistance, in violation of rI?itle 18, United
States Code, Section 666(a)(2), to wit, LORENZO, NG, YIN, IAN, and
PIAO agreed to pay and to facilitate the payment of bribes to an
individual serving as President of the United Nations General Assembly
and the Permanent Representative to the United Nations for
Antigua and Barbuda (?Antigua?), in exchange for official actions
on behalf of businessmen.

Overt Acts

3. In.furtherance:of the conspiracy and.to?effect the illegal

and cansed.to be committed in the Southern District of New York and
elsewhere:

a. On or about February 24, 2012, defendants FRANCIS
LORENZO, NG LAP SENG, a/k/a ?David Ng,? and JEFF C. YIN, a/k/a ?Yin
Chuan," caused the Permanent Representative to the UN for.Antigua,
in exchange for payments, to introduce a document at the UN in support
of a real estate project being developed by NO.

. On or about June 3 203.41c NG, LORENZO, and YIN arranged
for a $200,000 wire payment to a private bank account belonging to
the President of the UN General Assembly in exchange for the President
making a foreign visit to NO in his official capacity in order to
discuss progress on the real estate project being developed by NO.

c. ,On or about July 25, 2012, YAN?and PIAO arranged for
a $300, 000 wire from a co~conspirator not named as a defendant herein
to a private bank account belonging to the Permanent
Representative to the UN for.Antigua in exchange for advocating for
CC?l?s business interests with Antiguan government officials.

d. On or about November 4, 2013, IAN and PIAO arranged
for a $200,000 wire to a bank account belonging to the President of

2

the UN General Assembly from another co?conspirator not named as a
defendant herein in exchange for the President attending a private
conference in his official capacity.

(Title 18, United States Code, Section 371.)
COUNT TWO
(Payment of Bribes)

4. From at least in or about 2011, up to and including in or
about December 2014, in the Southern District of New York and
elsewhere, FRANCIS LORENZO, NG LAP SENG, a/k/a ?David JEFF C.
YIN, a/k/a ?Sheri Yan,? and HEKDIZHONG
PIAO, a/k/a ?Heidi Park,? the defendants, corruptly gave, offered,
and agreed to give a thing of value to a person, with the intent to
influence and.reward.an.agent of an organization, in.connection.with
a business, transaction, and series of transactions of such
organization, involving a thing of value of $5,000 and more, while
such organization was in receipt of, in any one year period, benefits
in excess of $10,000 under a Federal program involving a grant,
contract, subsidy, loan, guarantee, insurance, and other form of
federal assistance, to wit, LORENZO, NG, YIN, YAN, and PIAO,
facilitated and arranged for the payment of bribes to an individual
serving as the rresident of the United.Nations General.Assembly and
the Permanent Representative to the United Nations for Antigua in
exchange for official actions on behalf of businessmen.

(Title 18, United States Code, Sections 666(a)(2) and 2.)
COUNT THREE
(Conspiracy to Commit Transportation Money Laundering)

5. From at least in or about 2011, up to and including in or
about December 2014, in the Southern District of New York and
elsewhere, SHIWEI YAN, a/k/a ?Sheri Yan,? HONG-PIAO, a/k/a
?Heidi Park, the defendants, and others known and unknown, willfully
and knowingly'did.combine, conspire, confederate, and.agree together
and with.each.other to violate Title 18, United.States Code, Section


6. It was a part and an object of the conspiracy that SHIWEI
YAN, a/k/a ?Sheri Yan,? HONG-PIAO, a/k/a ?Heidi Park,? the
defendants, and others known and unknown, would and did knowingly
transport, transmit, and transfer, and attempt to transport,

3

transmit, and transfer, a monetary instrument and funds from a place
in the United states to and through a place outside of the United
States and to a place in the United States from and through a place
outside of the United States, with the intent to promote the carrying
on of specified unlawful activity, to wit, the bribery of a public
official, in violation of Title 18, United States Code, Section
1956(a)(2)(A), to wit, YAN and PIAO agreed to transmit payments to
the then~Prime Minister of Antigua through.Antigua?s Ambassador to
the United Nations in return for official actions.

(Title 18, United States Code, Section 

 

COUNTS FOUR AND FIVE

(Subscribing to False and Fraudulent U.S. Individual Income Tax
Returns) 

7. On or about the dates identified below, in the Southern
Bistrict and elsewhere, JOHN W..ASHE, the defendant, willfully and
knowingly, did make and subscribe to U.S. Individual Income Tax
Returns, Forms 1040, for the tax years set 
contained and were verified by the written declaration of ASHE that
?they were made under penalties of perjury, and which returns ASHE
did not believe to be true and correct as to every material matter,
to wit, ASHE fraudulently omitted.a total of more than $1.2 million
of income from his tax returns, including bribes received and the
purported salary ASHE paid himself as Fresident of the United Nations

as set forth below for the years set forth below:

 

 

 

 

     
i       
Four April 15, 2014 2013 $462,350.00
Five April 15, 2015 2014 $796,329.28

 

 

 

 

(Title 26, United.States Code, Section 7206(1), and.Title 18, United
States Code, Section 2.) 

The bases for deponent? knowledge and for the foregoing charges a
are, in part, as follows:

8. I havelbeerxa.Special.Agent with.the FBI for approximately
six years, and.I have been.personally involved in the investigation
of this matter, which.has been handled jointly by Special Agents of
the FBI and the Internal Revenue ServicewCriminal Investigation.

4

 

9. This affidavit is based in.part upon.my own observations,
my conversations with other law enforcement agents and others, my
review of email correspondence,lnw analysis of bank of records, my
examination of documents and reports by others, my interviews of
witnesses, and my training and experience. Because this affidavit
is being submitted for the limited.purpose of establishing probable
cause, it does not include all the facts that I have learned during
the course of the 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
specifically indicated otherwise.

OVERVI EW

10. As set forth in greater detail below, this case involves
businesspeople paying bribes to defendant ASHE, at the time
when he served as the United Nations Ambassador for Antigua and Barbuda
and as the 68th President of the United Nations General Assembly.
These bribes were facilitated by, among others, defendants FRANCIS
LORENZO, NG LAP SENG, a/k/a ?David Ng, JEFF C. YIN, a/k/a ?Yin Chuan, 
SHIWEI YAN, a/k/a ?Sheri Yam, and HEIDI HONG PIAO, a/k/a ?Heidi Park, 
who arranged.for the transmission.and laundering of over $1 million
of bribery money'from sources in.China. In.exchange for the bribes,
ASHE agreed to and did perform official actions for businessmen.who
were seeking benefits from the UN and the government of.Antigua and
Barbuda. Among other things, ASHE accepted over $500,000 of bribes
facilitated by LORENZO and YIN from NG, who was seeking to build a

(the ?UN'Macau Conference Center"). In.exchange for these payments
from NG, among other actions, ASHE submitted a UN document to the
UN Secretary General, which claimed that there was a.purported need
to build the UN Macau Conference Center. ASHE received
over $800,000 in bribes from various Chinese businessmen arranged
through.YAN and PIAO and, in.return for these bribes, ASHE supported
these businessmen?s interests within the United Nations and with
senior Antiguan government officials, including the country?s
then-Prime Minister (the ?Prime Minister?), with whom ASHE shared
a portion of the bribe payments.

 

3? The emails cited herein were obtained pursuant to search warrants

of the personal Yahoo, Gmail, and.AOL email accounts for defendants
JOHN ASHE, FRANCIS LORENZO, JEFF C. YIN, a/k/a ?Yin Chuan, SHIWEI
YAN, a/k/a ?Sheri Yan,? and HEIDI KONG PIAO, a/k/a ?Heidi Park.?

5

 

11. To funnel and help conceal the bribes to defendant JOHN
W. ASHE, defendants NG LAP SENG, a/k/a ?David Ng,? JEFF C. YIN, a/k/a
?Yin Chuan, SHIWEI YAN, a/k/a ?Sheri Yan, and HEIDI HONG PIAO, a/k/a
?Heidi Park, along with others, used non?governmental organizations
in the United States, which were purportedly established
to promote the mission and/or development goals.

12. During the course of the scheme, defendant JOHN W. ASHE
solicited and received bribes in various forms, including payments
to third?parties to cover personal expenses, suchensa.family
vacation and construction of a basketball court at his house in Dobbs
Ferry, New York. .ASHE also solicited a portion of his bribes to be
paid to two business bank accounts that ASHE opened at two major
American banks, in the name ?John Ashe dba John Ashe PGA 68,? and
?Office of the President of the General Assembly PGA 68 Operating
Account for the purported purpose of raising money for his UN General
Assembly Presidency (?PGAHAccountml? and Accountmz,? together,
the Accounts?). ASHE was the sole signatory on.both.of the PGA
Accounts. From in or about 2012, up to and including at least in or
about 2014, ASHE received over $3 million in the PGA.Accounts from
both foreign governments and individuals. During the same time
than $1,000,000 from.the PGA.Accounts and
transferred the money to his and his wife's personal bank accounts.
ASHE also used money transferred from the PGA Accounts to pay for
his personal expenses, such as paying the mortgage on his house in
Dobbs Ferry, paying his BMW lease payments, and buying luxury items
such.as Rolex watches. The majority of the funds that.ASHE withdrew
from the PGA Accounts were in the form of checks made out to ASHE
that ASHE signed himself, and had ?salary? listed in the check memo
line . During the same period of time, ASHE failed to report sufficient
income to the internal Revenue service to account for the
self?described salary and other funds he withdrew from the PGA
Accounts -. In total, ASHE underreported his income to the IRS by more
than $1.2 million dollars in tax years 2013 and 2014 alone.

RELEVANT INDIVIDUALS AND 

 

JOHN W. ASHE

13. From in or about 1989, up to and including in or about
December 2014, JOHN W. ASHE, the defendant, served in various
positions at the Permanent Mission of Antigua to the UN, which is
located in New York, New York.2 Beginning in or about May 2004, ASHE

 

2 ASHE no longer serves as a(diplomat any

6

served as the Permanent Representative of.Antigua.to the During
all times relevant to this Complaint, ASHE has been a lawful permanent
resident of the United States and has maintained.a house in
Dobbs Ferry, New York, which is located in Westchester County. Based
on my review of immigration file, I have also learned that
when ASHE applied to become an LPR, in or about October 2000, ASHE
waived.in.writing his assertitmLof any immunity that would.otherwise
accrue to him based on his occupational status as a diplomat.

14. I know from witness interviews and my review of publicly
available sources that on.or about June 13, 2013, JOHN W. ASHE, the
defendant, was elected as the 68th President of the UN General Assembly
for a one-year term beginning in or about September 2013
and ending in or about September 2014. The UNGA is comprised.of all
193 UN Member States, which elect a rotating President from one of
the Member States on an annual basis. Among other things, the UNGA
President presides over the current UNGA.session.and represents the
UNGA at various international economic and cultural forums.

15. I know from publicly available records that during each
of the years relevant to this Complaint, the United States Government
provided the UN with federal funds in excess of $10,000.

FRANCIS LORENZO, LAP SENS, a/k/a ?David Ng, and JEFF YIN, a/Jc/a
?Yin Chuan?

15. From in or about 2004, up to and including the present,
defendant FRANCIS LORENZO has been the Deputy Permanent
Representative to the United Nations for the Dominican Republic.
Based on my review of immigration records, I learned that LORENZO

 

other country. I understand from my discussions with the United
States Department of State that, at most, ASHE enjoys residual
official act immunity based on his former status as a diplomat from
Antigua from in or about February 2000 to in or about December 2014
and as President of the United Nations General Assembly from in or
about September 2013 to in or about October 2014- service in
these positions provides immunity only for conduct within the scope
of his official positions, which must be affirmatively asserted in
any judicial proceeding, to the extent he is permitted to do so
notwithstanding an immunity waiver he executed in connection with
becoming a U.S. legal permanent resident in or about October 2000.
Official act immunity does not provide protection from arrest and
does not cover conduct outside the scope of one?s official position,
such as the filing of false personal U.S. tax returns.

7

 

 

immigrated to the United States from the Dominican Republic in or
about 1985. In or about 1991, LORENZO became a naturalized United
States citizen. I understand frOm the United States Department of
State that, like defendant JOHN w. ASHE, LORENZO enjoys Official act
immunity, which must be asserted affirmatively and provides for
immnnity from criminal prosecution only for official acts taken in
connection with diplomatic position.

l7. In addition to being the Deputy Permanent Representative
to the United Nations for the Dominican Republic, investigation to
date has revealed that, since in or about 2009, defendant FRANCIS
LORENZO has also received funds from and served as an agent for
defendant NG RAP SENG, a/k/a ?David Ng,? a Chinese national and the
head of a major real estate development company based in.Macau (the
?Macan Real Estate Development Company?). In or about 2009, NG
founded.a particular NGO (?NGoul?) based in New York, New York, and
made LORENZO the ?Honorary President.? Since that time, NG has
regularly paid LORENZO a $20,000 salary and has also sent
additional payments to for which
sibling serves as the general manager. .According to its
website, is purportedly a ?21mlcentury media platform? whose
mission is to advance the implementation of the Millennium
Development Goals. Ehe website posts and links to content,
largely from external sources, relating to the UN, development, and
other topics. I know based on my review of documents that NG has funded
since its creation, and has wired or caused to be wired more
than $12 million from Macau to bank accounts of in New York,
New York.

18. a/k/a ?Yin.Chuan,? is the principal
assistant to defendant NG SENG, a/k/a ?David Ng,? and_also has
used.the title of Assistant to the General Manager of YIN is
a naturalized United States citizen who was originally born in China,
and.resides in China. For at least several years, YIN has assisted
NG with, among other things, communicating on his behalf, wiring money
to the United States, making travel plans to and from the United
States and arranging meetings for NO in the United States . YIN serves
as principal interpreter when NO is in the United States, travels
with.him to the United States, and.is generally present for meetings
NG has in the United States, taking notes and handling documents,
among other things.

19. Based on.my review of documents and my conversations with
other law enforcement agents, I know that defendant JEFF C. YIN, a/k/a
?Yin Chuan,? has frequently traveled to the United States with
defendant NG-LAP SENG, a/k/a ?David Ng,? with.large amounts of cash.

8

For example, on or about March 6, 2014, YIN and NG arrived at John
F. Kennedy International Airport with $300,000 in cash.
Approximately-five weeks later, on or about April 18, 2014, YIN and
NG arrived at JFK with $300,000 in cash? .Approximately two months
later, on or about June 13, 2014, YIN and NG arrived at Teterboro
Airport in New Jersey with $390,000 in cash? More recently, on or
about July 5 2015 YIN and NG arrived by private plane in Anchorage,
Alaska with $900,000 in cash. Two days later, YIN and.NG flew on to
New York City. On or about the following day, YIN and NG met with
defendant FRANCIS LORENZO met at a hotel in New York, New York. Most
recently, on or about September 16 2015 YIN and NG arrived by private
plane in Anchorage,.Alaska with $500,000 in cash. They then flew<mi
to New York.3

SHIWEI YAN, a/k/a ?Sheri Yen, and HEIDI HONG PIAO, a/k/a ?Heidi Park?

20. Defendants SHIWEI YAN, a/k/a ?Sheri Yan,? and HEIDI HONG
PIAO, a/k/a ?Heidi Park,? are naturalized United.States citizens who
were born in China and who reside principally in China. Based on
my review of documents, I know that YAN and PIAO are associated.with
several businessmen in China. YAN is also the Chief Executive
Officer of an NGO previously based in Washington, D.C.,
now based in New York, New York, and PIAO is Finance Director.
is purportedly an organization created to promote global and
sustainable economic development. In August 2013, YAN and PIAO
began paying defendant JOHN W. ASHE approximately $20,000 a month
in connection.with.his serving as the ?Honorary Chairman? of 

 

3 Based on my participation in the arrests, I know that NO LAP

SENG, a/k/a ?Bavid Ng,? and JEFF C. YIN, a/k/a ?Yin Chuan,? the
defendants, were arrestedcnlor about.September 19, 2015, and<aharged
in Complaint 15 Mag. 3369 with conspiracy to make falSe statements
and to defraud the United States arising from their travels to the
United States with large amounts of cash and explanations provided
to authorities regarding that cash.

9

 

 

THE BRIBERY . SCHEME

ASHE RECEIVES PAYMENTS ARRANGED BY LORENZO IN EXCHANGE FOR OFFICIAL
ACTIONS ON BEHALF OF NG

NG and LORENZO Make Payments to ASHE In Return For ASHE Promoting
Business Dealings With The Government of Antigua

21. As described in.more detail below, in or about the Spring
of 2011, NG LAP SENG, a/k/a ?David Ng," and FRANCIS LORENZO, the
defendants, began making payments to JOHN W. ASHE, the defendant,
and wife in return for, among other things, ASHE using his
lucrative investments
in Antigua.

22. Based on my review of emails and other documents, I have
learned that in or about the Spring of 2011 defendant FRANCIS LORENZO
asked defendant JOHN W. ASHE to travel to China to meet with defendant
NG LAP SENS, a/k/a ?David Ng,? about potential investment 
opportunitiesforlKEinAntigua. 
invitation, when it did not appear that ASHE would be compensated
for taking the meeting, ASHE agreed to make the trip after LORENZO
informed ASHE that which was at least in substantial part funded
by NO, would pay for ASHE and 3 family to take an unrelated family
vacation to New Orleans, Louisiana. On or about April 4 2011, after
ASHE agreed to fly to China travel
itinerary for ASHE, his wife, and two children,_which included
first?class plane tickets from New York to New Orleans and a hotel
reservation for $850.00 per night. LORENZO later emailed.ASHH that
would pay for the trip through travel agent.

23. Based on my review of emails and travel records, I know
that after defendant FRANCIS LORENZO told defendant JOHN W. ASHE that
would pay for family vacation to New Orleans, ASHE
traveled to Hong Kong and Macau between April 17 and 20, 2011.
According to a post?trip report sent to LORENZO by another 
employee, during the trip, ASHE:and.others met with ?private sector?
individuals in Macau, which is where defendant NG LAP SENG, a/k/a
?David Ng,? was based. On.April 20, 2011, ASHE emailed.LORENZO from.
the Hong Kong airport as ASHE was about to board.his flight home and
told LORENZO, ?Thanks again to you and.Ng for everything." Shortly
after arriving in New York from his meeting with NS in Macau, ASHE
and.his family left for the family'vacation.to New Orleans for which
LORENZO agreed to pay.

10

24. On April 26, 2011, less than a week after defendant JOHN
W. ASHE returned from Macau and the day after he returned from
the family'vacation.toINeW'Orleans emailed.defendant FRANCIS
LORENZO and offered to set up a meeting between defendant NG LAP SENG,
a/k/a ?David Ng,? and a particular Antiguan government minister
(?Antiguan Minister?1?). Specifically, ASHE emailed LORENZO that
?[dJuring the visit to Macao/Hong Kong it just occurred.to me that
it would be good idea if [Antiguan Minister~1] could visit and.meet
Ng, [a second Chinese businessman} and possibly [a third Chinese
businessman]. Let me know what you think and if there?s a date in
early June you would want me to suggest to the Minister.?

25. Based on my review of emails and travel records, I know
that following defendant JOHN trip to Hong Kong and Macau
to meet with defendant NG LAP SENG, a/k/a ?David Ng? (and the vacation
to New Orleans which he demanded in return) ASHE traveled to Antigua
between April 26, 2011 and April 29, 2011 . On or about April 30, 2011,
after ASHE returned from Antigua, ASHE emailed defendant FRANCIS
LORENZO to inform him that ASHE had arranged for the then-Antiguan
Prime Minister telneet'with NG-and.others about ?concrete investment
opportunities, including the immediate acquisition of hotel,
properties.? In the same email, ASHE told LORENZO that ASHE was
expecting to spend $30,000 in connection with the upcoming'
construction.of a.private basketball court at house in Dobbs
Ferry, in Westchester County, New York, commenting ?[llet?s discuss
on Monday." 

26. Based on my review of emails and travel documents, I know
that on or about June 20, 2011, defendant FRANCIS LORENZO and two
other employees made a trip to Antigua, which.was arranged.by
defendant JOHN W. ASHE. E-mails reflect that during his trip to
Antigua, LORENZO met with the Prime Minister. Following the trip,
ASHE sent an email to LORENZO about discussion with the
Prime Minister concerning the Prime Minister?s travel to New York
in September 2011, nominally to attend an award ceremony to be hosted
by nsomi.

27. During the same period.of time that defendant JOHNVW.ASHE

Ng,? and defendant FRANCIS LORENZO and the Prime Minister, ASHE
continued to solicit payments from LORENZO in connection with the

example, on September 9, 2011, ASHE emailed.LORENZO that his family
had ?obtained final approval from our Village?s Planning Board to
proceed.with.the construction.of the basketball court? and,that.ASHE
would keep LORENZO informed about the estimated construction cost

11

 

 

 

from the contractor. On October 18, emailed.LORENZO the
contractor?s proposal for the basketball court, which included a
$20,000 down payment due to the contractor. .ASHE told LORENZO that
ASHE would be grateful if LORENZO ?could make [arrangements] for a
check in the amount be mailed directly to [the contractor] (at the
address given at the top of the proposal) prior to 
departure to [Hong Kong}.?

28. In.additits1to soliciting payments for his family'vacation
and basketball court installation, in or about May 2011, defendant
JOHN W. ASHE arranged through defendant FRANCIS LORENZO to begin
paying wife as a purported ?consultant? for On May 19 
2011, ASHE sent LORENZO an email stating ?here?s the banking
information for the consultant option we decided on? followed by bank
account wife. I know
from.my review bank records, that between January 2011 and at least
December 2014, NGowl paid wife $2,500 per month. .According
to tax filings made by ASHE and wife, wife claims to
work as a ?climate change consultant" for although based on
my review of documents and emails I have been unable to
determine what actual work, if any, wife has actually done
for . In fact, based on my review of emails, I know that LORENZO
and other employees regularly emailed ASHE himself, and not
wife, when the $2,500 check to wife was ready
to be picked up at offices in New York, New York.

29. At the same time that defendant JOHN W. ASHE and his wife
were receiving payments and gifts from ASHE arranged.for the
Prime Minister tC)meet with.defendant.NG LAP SENS, a/k/a ?David Ng,?
in.New York. Basedcminnrreviemrof emails and travel records, at the
request paid for first~class airline tickets for the
Prime Minister and six other Antiguan officials to fly to New York
during the week of September 2011, when both 8 ?award ceremony?
and the annual UNGA meeting was taking place.4 Based on my review
of travel records andiother'documents, I know that the Prime Minister
traveled to New York between September 18, 2011 and September 25,
2011 and paid.for the airfare for the Prime Minister and his
delegation as well as their hotel rooms in New York . Based on my review
of travel records, I also know that NG arrivedin New York on or about
September 18, 2011. On September 20, 2011, ASHE emailed defendant
FRANCIS LORENZO that ?[t]he PM has confirmed his availability for

 

4 ASHE also requested that pay for the Prime Minister to

travel to other cities within in the United States during the week
following the UNGA meeting in 2011.

12

the proposed meeting with the investor on Thursday [September 22,
20ll].? -

NG and LORENZO Continue Payments to ASHE and His Wife In Exchange
For an Official UN Document From ASHE in Support of NG's Macau
Conference Center 

 

30. As described.below, beginning in or about September 2011,
following payments to defendant from the NGO funded by
defendant NG LAP SENG, a/k/a ?David Ng,? and arranged through
defendant FRANCIS LORENZO, for official action in promoting
business interests in Antigua, NG and LORENZO arranged for
additional payments to ASHE so that ASHE would use his position
representing a member state at the United Nations to cause the UN
to promote a conference center in Macau being developed by NO.

31. Based.on.my review of e?mails and other documents, I know
that since at least 2010, defendant NG LAP SENG, a/k/a ?David Ng,?
and the Macau Real Estate Company have been encouraging the
developmentcifanlexpansive conference facility in Macau, which.they
have touted as ?The Permanent International Conference Center for
the United Nations South?South Cooperation. According to a brochure
for the UN?Macau Conference Center, the multi?billion dollar center
is proposed to house, among other things, a ?Global Business 
Incubator,? which ?will serve as a facilitator to governments and
the private sector to build the capacity of South?South countries
to leverage innovation and creativity in achieving the Millennium
Development Goals.?

32. I know based on my review of emails and other documents
that in the months following September 2011 defendant SOHN W. ASHE
began advocating for the development of the UN Macau Conference Center
of defendant NG LAP SENG, a/k/a ?David Ng.? Based on my review of
emails, I know that on November 11, 2011, a ?development consultant?
for (the Development Consultant?) drafted a letter
purportedly addressed from the Antiguan Prime Minister (the ?November
2011 Letter?), which highlighted the supposed importance of
developing a Global Business Incubator such as the one anticipated
to be housed by UN Macau Conference Center. The Development
Consultant emailed.the November 2011 Letter for his approval
and copied defendant FRANCIS LORENZO. After receiving the November
2011 Letter, ASH?igave his approval for the November 2011 Letter and
told the Development Consultant that NCO-1 was authorized to
sign the letter on behalf of the Prime Minister.

13

 

 

33 . Approximately one month after authorizing the November 2013.
Letter in support of the Global BuSiness Incubator being developed
by defendant NG LAP SENG, a/k/a ?David Ng,? defendant JOHN W. ASHE
solicited additional payments from NG through defendant FRANCIS
LORENZO. Specifically, on or about December 19, 2011, ASHE emailed
LORENZO and another employee of (the Employee?) to
request that NG-begin contributing funds to anticipated UNGA
Presidency. In.the email, ASHE Employee,
insum and substance, that ASHE had recently received the endorsement
of the UN Group of Latin American and Caribbean States, which he
believed.meant that his election as the UNGA.President in.June 2013,
some later} was virtually guaranteed. .ASHE further stated
that NG had indicated when they met in China that NG would ?assist?
ASHE in ?whatever way necessary? to make Presidency a
?success.? ASHE then stated he was faced with the ?daunting task?
of raising sufficient funds to ?ensure that my tenure as PGA is a
successful one? and that ?[a]gainst this backdrop, Ng?s promise to
assist is indeed very welcome and absolutely essential.? ASHE
attached to the email a document outlining his official powers as
the expected UNGA President and.ASHE's goal of soliciting'more than
$3,000,000 for his Presidency. .ASEE asked LORENZO and the 
Employee to pass on the proposal to NG.

34. I know from.my review of emails that on February 9, 2012,
defendant FRANCIS LORENZO emailed defendant ASHE to propose
that they meet the next day. Later that same night, the 
Development Consultant emailed LORENZO a draft document to be
submitted.by ASHE to the UN Secretary General claiming that.Antigua
and other countries had recently launched a Global Business Incubator
such.as the one proposed.to be housed.by defendant.NG LAP SENG, a/k/a
?David Ng?s? UN Macau Conference Center (the ?Draft UN 
On February 15, 2012, the Development Consultant sent LORENZO
an updated version of the Draft UN Document, which LORENZO then
forwarded to ASHE. Three minutes after sending ASHE the Draft UN
Document, LORENZO sent.ASHEian.email stating, ?John.remember to send
your driver tomorrow afternoon to pick up the check.? Bank records
reflect that on February 15 2012, wrote a $2 500 check to 
wife that was then deposited into ASHE and his wife?s joint bank
account on February 16, 2012.

35. I know1?mmnnurrevieW'of emails that, between.Eebruary'15,
2012 and February 23 2012 defendants JOHN W. ASHE and FRANCIS LORENZO
revisions and
comments to the Draft UN Document, which, in sum and substance,
promoted.the launching ofeac?obal Business Incubator, identical to

14

the one defendant NG LAP SENG, a/k/a ?David Ng,? was seeking to be
housed by the UN Macau Conference Center.

36. On February'24, 2012, after defendant JOHIIW..ASHE and his
wife in.cast1payments 
and had solicited other things of value such as a family vacation
and the private basketball court described above, ASHE introduced
document in.support of the Global Business Incubator, which.was
substantially identical to the Draft UN Document sent to ASHE by
defendant FRANCIS LORENZO. Specifically; on February'za, 
signed UN Document Number (the ?Official UN Document?), a
letter from ASHE to the UN Secretary General concerning the Global
BuSiness Incubator. In the Official UN Document, ASHE stated that
the Antiguan Prime Minister and other heads of state had decided to
launch a Global Business Incubator at a meeting hosted by on
September 23, 20ll. The Official UN'Document claimed.that there was
?a need for a Global Business Incubator, to harness the potential
of small businesses through ICT [information and communications
technologies] and through greater access to global markets.

The Global Business Incubator will serve as a facilitator for
Governments and the private sector in building the capacity of
developing countries to leverage innovation and creativity in
achieving the Millenniunlbevelopment Goals.? After submitting
the Official UN'Document, ASHE emailed a copy to LORENZO and stated,
?As agreed, the" request has been submitted. On March 26, 2012 after
the Official UN Document had been processed and assigned a formal
document number, ASHE emailed a copy of the Official UN Document with
the document number to LORENZO and said, ?The final product.?

37. After defendant JOHN W..ASHE sent the Official UN Document
in support of the UN Macau Conference Center to the UN Secretary
General, defendant FRANCIS LORENZO, and defendant NG LAP SENG,
a/k/a ?David Ng," used the document to promote the building of the
UN Macau Conference Center. For example, March 20, 2012, LORENZO
forwarded the Official UN Document to the Secretary General of the
International Telecommunication Union, which is a specialized agency
of the UN dedicated.to information and communication technologies.
On.April 18, 2012, LORENZO forwarded the.Official UN Document again,
this time to an executive at UN Habitat. And on October 23, 2012,
LORENZO forward the Official UN Document to an investment banking
firm based in Hong Kong. In each of these instances, LORENZO used
the existence of the Official UN Document to imply that the conference
center NG was seeking to develop was likely to be supported in some
fashion by the United Nations.

'15

 

LORENZO and YIN Arrange for Additional Payments From NC to ASHE and
His Wife To Obtain Additional Official UN Support for UN Macau
Conference Center

 

38. As described in more detail below, between in or about
January 2013 and through defendant JOHN W. UNGA Presidency,
which ended in or about September 2014, defendants NG LAP SEING, a/k/a
?David Ng,? JEFF C. YIN, a/k/a ?Yin Chuan,? and FRANCIS LORENZO
arranged for hundreds of thousands of dollars in additional payments
to ASHE so that ASHE would continue to push for UN support for 
Macau Conference Center.

39. I know from my review of emails that, after defendant
FRANCIS LORENZO successfully arranged for defendant JOHN W. ASHE to
submit the Official UN Document in support of the UN Macao. Conference
Center in or about February 2012, defendants NG LAP SENG, a/k/a ?David
Ng, f? and JEFF C. YIN, a/k/a ?Yin Chuan, later became impatient with
the pace of continued progress towards the development of
the UN Macau Conference Center. ?For example:

a. On January 5, 2013, YIN emailed LORENZO with the
subject line ?From Ng. YIN said that NG had instructed YIN to write
LORENZO and that NG wanted to meet with LORENZO in New York the
following week. YEN added that ?top priority right now? was the
UN Macau Conference Center and that NG wanted LORENZO to prepare a
brochure for the UN Macau Conference Center that included the 
approval document.?

b. On January 29, 2013, after 3 meeting with NO
in New York earlier that month, YIN sent LORENZO another email with
the subject line ?Urgent told LORENZO, ?The urgent'
matter as of now is that Mr. Ng has given you a deadline to complete
the task of obtaining approval for the Convention Center proj ect.?
YIN added that ?your 30k for month of jan will be wired tomorrow,
along with Feb, so that makes it 60 to be received. LORENZO replied
?Jeff I started working on it and I am waiting for the transfer to?
speed the process.?5

 

5 I know from my review of bank records and emails, that beginning

in or around this time LORENZO began receiving wire transfers
from of $30, 000 per month to a company based in the Dominican
Republic for which sibling serves as the general manager.
These payments were in addition to the approximately $20 000 per month
that EJORENZO received from as his salary as President of .

l6

C. Onilune 1,22013, 
YIN 
that one of the topics to be discussed with NG was a ?project update.?

40. Following these repeated demands from defendants JEFF C.
YIN, a/k/a ?Yin Chuan,? and NG LAP SENG, a/k/a ?David Ng,? that
progress be made on the UN Macau Conference Center, defendant FRANCIS
LORENZO arranged for defendant.JOHN W. ASHE to approve a revised
Official UN Document (the ?Revised Official UN Document?), which
specifically promoted Macau Real Estate Company as the developer
for the proposed Global Business Incubator. Specifically, I have
learned the following from.my review of emails and other documents:

. a. On.May 23, 2013, LORENZO emailed.ASHE a draft of the
Revised Official UN Document, which was substantially similar to the
original Officialt?JDocument, except that,ir1additiontx>promoting
the Global Business Incubator, letter to the UN Secretary
General added a paragraph that stated, am pleased to inform you
that in response to the recommendation [for a Global Business
Incubator], [the Macau Real Estate Company] of China has welcomed
the initiative and will serve as the representative for the
implementation of the permanent Expo and meeting Center for the
country of the south [sic]. This is one of the first centres in the
network of incubator centres in a public-private partnership with
the support of and leading partner In his email to ASHE,
told ASHE that, ?[a]fter speaking with [a particular UN
official in reference to the paragraph that need
to be inserted in.the letter he said that the letter will be the same
the only thing that they will do is put Rev.l and add the paragraph.
He said that it will be easy this way.?

b. Onllune S, 2013, after'emailing the document.to ASHE,
LORNEZO emailed the draft Revised Official UN Document to UN
Official?l and added in the body of the email: ?As per our
conversation enclose [sic] see the letter that I sent you before so
you can advise me if it is ready. UN Official?i emailed LORENZO back
the next morning and told him that the document would be issued by
Monday, June 10, 2013.

c. On Monday, June 10, 2013, another UN employee emailed
LORENZO and ASHE the final Revised Official UN Document. Ehe Revised
Official UN'Document was substantially similar to the draft version
sent by LORENZO to ASHE as described above. Specifically, the Revised
Official UN Document was a letter from ASHE to the Secretary General
promoting the development of a center built by Macau Real Estate

17

 

Company to host a Global Business Incubator. The Revised Official
UN'Document had the same UN'document number as the original Official
UN Document but contained.a footnote claiming that the document was
supposedly reissued for ?technical reasons.?

I know from my review of bank records that between
on.or about January'l, 2013 and.the date that.ASEE?s Revised Official
UN Document was issued, ASHE and his wife received approximately
$100,000 from In addition to wife $2,500
payment, on February IS, 2013, wrote a $25,000 check to ASHE
directly. Moreover, beginning in or about April 2013, ASHE started
receiving $10, 000 a month from another NGO related to for which
LORENZO is also the President 

41 . After defendants JOHN W. ASHE and FRANCIS LORENZO arranged
for the Revised.Official UN Document in support of defendant NG LAP
a/ k/ a ?David Ng" s? defendant
JEFF C. YIN, a/k/a ?Yin Chuan,? continued to demand that further
progress be made towards the development of the project. For example,
I know from my review of emails the following:

a. On July 22 2013 YIN emailed LORENZO and told LORENZO
that NG wanted.a ?[p]rogression report for the Expo/Meeting Center?
as soon as possible. On July 25, 20.13, LORENZO emailed YIN that  11
reference to the Center I am waiting for you to send me the proposal
so I can move forward with the Unit and UN HABITAT I have
met with them already and they are waiting to see the proposal with
the financing.?

b. On August 29, 2013, YIN emailed LORENZO and told
LORENZO that NG would be in New York the next day to discuss with
LORENZO the update on the ?Expo/Meeting center.?

c. On.November 19, 2013, YIN sent LORENZO another email
demanding that progress be reported on the UN Macau Conference Center
because NO was ?extremely un?satisfied with the progression.? YIN
further that unless progress was made, ?[t1he wire will
be on halt.?

42. Following these continued demands by defendants JEFF C.
YIN, a/k/a ?Yin Chuan,? and NG LAP SENG, a/k/a ?David Ng," that
defendant FRANCIS LORENZO show progress on the development Macau
Conference Center, LORENZO arranged for defendant JOHN W. ASHE to
travel to Macau with other UN officials to meet with.NG in exchange

18

for a $200, 000 payment to one of PGA Accounts. Specifically,
I have learned the following:

a. Chlor'aboutllanuary'ZZ, 2014, LORENZCxemailed.YIN'and
told him that LORENZO had met with office and that the best
dates for ASHE to visit Macau were March 22 and 23, 2014. YIN
responded, ?Let me confirm with Ng, is this an official or unwofficial
visit?? LORENZO responded, ?0n official.? Later, on or about
February 18 203.4 YIN wrote LORENZO again and said that NO had changed
his mind and was requesting that visit to Macau be an ?official
visit.?

b. On.or about March.3, 2014 three days before NG and
defendant YIN landed at JFK with $300, 000 in United States currency,
as described.in paragraph 19 emailed LORENZO and told LORENZO
to meet NC at a restaurant on March 6, 2014 . YIN further told LORENZO
?we have a few things that have been outstanding for a long time:

. Iternary'[sic? PGA.[President.of General
Assemblyi .. .[and] History
and progression of the approval document for the Expo Center.?

c. On March 4, 2014, LORENZO emailed ASHE a formal
?Special Invitation? from the Macau Real Estate Company and 
for ASHE to travel to Macau between March 22 and March 23, 2014.
According to the invitation, ASHE would be accompanied on the trip
by ?Chef de Cabinet, who is also the Permanent Representative
of a different country to the UN, and Special Assistant to
the President. .According to the ?Preliminary'Agenda? for the trip,
on March 22, 2014, ASHE and the other UN officials were scheduled
to arrive at the Hong Kong.Airport, where they would be greeted by
the Macau Real Estate Company, and then they would be flown by
helicopter to Macau. Later that day they would.attend.aineeting and
presentation by the Macau Real Estate Company at one of the company? 
real estate development sites to be followed by a ?formal dinner.?
After spending the night at a luxury hotel in Macau, delegation
would then fly back home the next day.

d. On March 5, 2014, ASHE emailed LORENZO in response
to the formal invitation? ASHE wrote that am asking to make
a contribution the the [sic] Office of the he wants visit Macau to see his project. . . . Even though
Ng has made a lot of empty promises in the past, I am willing to travel
to Macau to see his project, since it is important to him. But it
has to made absolutely clear to him that I will not go unless I see
the funds - funds which are NOT for my personal use but to help run
the PGA office. Period? Please let them know that I am requesting

19

 

somewhere between_$100 and to be deposited.in the following
account: [information.for PGAHAccount42].? As described.above, and
set forth in detail below, even though ASHE claimed that the funds
he was requesting from NG in order to travel to Macau were not for
his personal use, the PGA Accounts were set up by ASHE personally
and he transferred almost $1,000,000 from the PGA Accounts to his
other personal bank accounts.

e. On or about March 20, 2014, YIN sent an email to an
email account that appeared to belong to a travel company based in
Hong Kong. YiN?s email stated, among other things, ?My guests are
from the United Nations and then listed four individuals, including
ASHE, LORENZO, Chef de Cabinet, and Special.Assistant.

f. I know from my review of travel records, that ASHE,
Chef de Cabinet, and Special Assistant flew to Hong
Kong on.or about March 22, 2014 and flew back to New'York on.or about
March.23, 2014, which.is consistent with the agenda contained in the
?Special Invitation? from Macau Real Estate Company and 


g. In April 201%, shortly after ASHE and 
meeting with NG in Macau, NG set up a non?profit Delaware corporation
(the ?Delaware Corporation?) with NG as its Chairman and LORENZO as
its President. reviewed, the Delaware
Corporation is purportedly ?a nonprofit organization that was
launched during the session of the General Assembly, in
response to the [Revised Official UN Eocument]. [The Delaware
Corporation] has been appointed.to serve as the representative for
the implementation of the permanent expo center. It is one of the
first centres in the network of incubator_centres in.pnblic~private
partnership, with the support of leading partner 

h. On or about May 22, 2014, approximately two months
after ASEE's visit to meet NO in Macau, LORENZO emailed YIN the
following: ?Jeff[,] see the bank account of the PGA [President of
General Assembly] office. Try to send that wire as soon possible and
when you send it let me know so i can advise him. There are a lot
of things that need to be done here._ He want to know when Ng will
cOme here[.] II am Working to get the things we Following
the text of the email, LORENZO listed the bank account information
for RGA Account~2. On June 2, 2014, ASHE forwarded the
information for PGA Accountw2 to LORENZO again.

20

i. I know based on my review of bank records that, on
or about June 3, 2014, wired $200,000 
I also know that between.January 2014 and.June 2014, during the time
that ASHE agreed.to meet with.NG and.visit his project in.Macau with
other UN officials, and had paid approximately $50,000
to ASHE and his wife.

42. Based on, among other things, my review of emails, I know
that construction has not yet started on the UN Macau Conference
Center. I know from my review of a brochure for the UN Macau Conference
Center that the project had been scheduled to ?launch? at an event
hosted by the Macau Real Estate Company on December 20, 2014, in
conjunction.with a ?Higthevel Partnership Forum.On The Importance
of Creative Economy South~South Cooperation and ICT To Achieve
Sustainable Development.? According to the brochure, the ?Opening
Address? for this program was scheduled to be given by ASHE.

43. On or about September 19, 2015, following his arrest on
the charge<describednabove, defendant.IEFE?C. YIN, 
waived his Miranda rights and was interviewed by the FBI. During the
interview, which was recorded, YIN told FBI agents, among other
things, that his co?defendant, NG-LAP SENG, a/k/a ?David Ng,? viewed?
the building of the UN Macau Conference Center as ?legacy? in
Macau. YIN further admitted that NG, assisted by YIN, had made
payments to obtain official action from the UN on this project.

YAN AND PIAO ARRANGE PAYMENTS TO ASHE IN EXCHANGE FOR OFFICIAL ACTIONS
OF VARIOUS CHINESE BUSINESSMEN

44. Based on my review of emails and travel records, I know
that defendant JOHN W. ASHE: traveled to Hong Kong in April 2012 where
ASHE met with defendants SHIWEI YAN, a/k/a ?Sheri Yan,? and HEIDI
SONG PIAO, a/k/a ?Heidi Park.? meeting with.YAN and PIAO was
in or around the same time period that ASHE had stated to defendant
FRANCIS LORENZO, in sum and substance, that ASHE was virtually assured
of being elected.the UNGA President and that he was hoping to secure
more than $3 000, 000 for his Presidency. After meeting ASHE in Hong
Kong, YAN and PIAO, as described.in more detail below, arranged for
hundreds of thousands of dollars of bribes to be paid to ASHE in return
for, among other things, ASHE taking official action on behalf of

 

5 Five days later, on.or about June 8, 2014, ASHE emailed.LORENZO

and stated: ?Going to Antigua on Thursday to vote and would need to
take something for the PM. Hope I can have the $26 in cash.before
then.?

21

 

 

various Chinese businessmen seeking to obtain lucrative investments
and government contracts in Antigua and elsewhere.

YAN and PIAO Facilitate a $300 000 Bribe to ASHE On Behalf Of a Chinese
Media Executive

 

 

45. Shortly after JOHN W. ASHE, the defendant, met with
defendants SHIWEI YAN, a/k/a ?Sheri'Yan,? HONG-PIAO, a/k/a
?Heidi Park? in Hong Kong in April 2012, YAN and PIAO facilitated
a $300,000 payment on behalf of a co?conspirator not charged
herein a Chinese media executive seeking to invest in
Antigua and potentially to obtain Antigua citizenship for himself
or others. Specifically, I have learned the following based on my
review of emails, bank records, and other documents:

a. May 29, 2012, YAN emailed ASHE to report
that think we have secured to which.ASHE responded 
View of the new and.positive developments, I look forward.to meeting
with you in New York or somewhere else if that is possible.?

b. On or about July 17, 2012, ASHE met 
in New York. The next day, ASHE emailed YAN and PIAO the account
information for FGA Account?l and stated ?please find below the
related info for the matter we discussed yesterday to get the ball
rolling." ASHE added that ?this will be the account for the PGA
funding as well." YAN'emailed ASHE back, ?Greati Thanks!? and.?IAO
emailed ASHE, shall get to work on it right away.?

c. On July 23 2012, YAN sent the following email to ASHE,
copying PIAO: ?Dear John, a quick note to let you know that I will
send.first $300.000 tot?naaccount this week. Sheri.? 'Theznext.day,
on July 24, 2012, PIAO sent an email to ASHE, with a copy to KAN,
stating the following: ?Just got the notice that the $300,000 will
be in your account by tomorrow, please check to receive . This 300 000
is from 10% of 3M just to show his goodwill.? In response
ASHE wrote ?Will inform the bank. Thanks for the efforts.?

On or about July_25, 2012, PGA Accountel received a
$300,000 wire from a partiCUlar individual (?Individual?l?) who is
an American citizen based in the United States and is a business
associate of YAN and PIAO, who YAN.and PIAO have repeatedly asked
to wire money on their behalf at times relevant to this Complaint.
Following receipt of the wire, ASHE wrote to YAN and PIAO: wish
to confirm receipt of the first tranche of funds in the amount of
$300,000.?

22

e. The next day, on July 26, 2012, ASHE sent an email
to YAN and PIAO telling them, in sum and substance, that ASHE would
travel to Antigua to advocate for Cle?s business interests with
Antiguan.government.now that had Irlparticular,
ASHE stated the following to YAN and PIAO, in relevant part:

This bring [sicl me then to and more
importantly this initial contribution of
$300,000. As I recall from our discussions,
these funds were intended as a show of ?good
faith? by him re. his interest in developing a
base/hub in Antigua and Barbuda AND (equally
important) enable me to demonstrate to my
interlocutors that he is indeed serious. To be
totally upfront then, the funds in question will
allow me to ?start the conversation? (my exact
words when.we last met) when.I visit Antigua in
the next week or so.

After our discussions last week, and given the
long lead time it takes to get things moving 
even in a small country such as my own I had
already alerted.my interlocutors in.Antigua to
anticipate ?show?of?good faith.? It
was against this backdrop that my visit to
Antigua was planned.

f. On.August 4, 2012, ASHE emailed.YAN?and PIAO that he
would.be traveling to.Antigua in the coming days. ASHE told YAN?and
PIAO that he was traveling to Antigua in order ?to begin the
?conversationf on initiative with the folks?down.therevery short visit, the sole purpose of which is
to get my superiors to focus on the this [sic] important initiative
and to lay the groundwork for s] future meeting with the decision
makers on my side. Most if not all of the initial contribution
you have forward to account will be used on this trip so any additional
contribution(s) to the account before Thursday would be most
welcomed.?

g. Three days later, on or about August 7, 2012, ASHE
sent an email to YAN and PIAO stating, in relevant part:

23

 

I am trying to . opening a direct channel to the top
decisionmaker, the Prime Minister (with whom I will be

meeting, one~on~one when I arrive in Antigua on Thursday) .
The plan.is to sell [the Prime Minister] on the initiative
AND arrange for him to meet with (and.co.), either
here in NY in.September, when he (the PM) comes up for the
UN'General?next month, to be followed.by a visit by 
(and co) to Antigua in early October. This way, the PM will
determine whether or not he needs to involve other levels
of government and at what time.

. As an.aside, my brother heads the Financial Services
Regulatory Commission (FSRC), which is the independent
authority responsible for approving the establishment of
offshore banks (a goal of you may recall) and the
Minister of Finance is a high school classmate of mine.
The point here is that, after meets the Prime
Minister and he subsequently travels to Antigua, he will
be able to meet all the folks who matter. 

h. ASHE traveled to Antigua between on or about August
9, 2012 and August 11, 20l2. On.the same day that.ASHE returned from
Antigua he emailed YAN and PIAO the following, in relevant part:

Madam S/Madam H,

Just returned from Antigua about 90 mins ago and thought
I better pen this while it is fresh in mind.

Although I was only in Antigua for 48 I did managed
[sic] to meet with all the key decision.makers to discuss
plans; that I had the initial resources in hand
as proof of his intentions (and which have now been fully
utilized), certainly served the intended purpose of
focusing minds and getting the conversation started. Ends
result: I have been.given the green light to fully engage
and to mutually agree on a way forward. . 

PZAO replied to email: ?Thank you for the wonderful news, only
you can bring this matter up to the highest level within such a short
time. Sheri met with [CCwl] earlier today, and gave him a briefing,
he was very pleased to hear the good news.??

24

46. From my review of bank records for PGA.Account?l, I know
that defendant JOHN W. ASHE disbursed the bulk of $300,000 payment
from CCwi discussed above as follows:

a. ASHE sent $100, 000 to the Prime Minister, in a series
of five $20,000 checks

b. 
of the Prime Minister.

c. ASHE paid approximately $40,000 to a BMW dealership
in Manhattan, where ASHE signed a lease for 2013 BMX model X5.

d. ASHE paid approximately $35,000 to a credit card
company used by him and his wife. ASHE used the money to pay off
balances that he and his wife had accumulated from charges for
purchases such as online shopping, restaurants, massages, video
games, sporting goods, and his wife?s personal travel.

e. ASHE transferred $20,000 to his joint bank account
with his wife and withdrew another $13,500 in cash.

YAN Payments to ASHE After He Is Elected.?NGA
President

 

47. Based on my review of emails and other documents, I know
that after defendant ASHE was elected.UNGA.President in.June
2013, defendants SHIWEI YAN, a/k/a ?Sheri Yan,? HONG-PIAO,
a/k/a ?Heidi Park,? began making payments of approximately
$20,000 to ASHE under the guise of being the ?Honorary Chairman? of
with which ASHE had no prior involvement or knowledge.
Specificallyy I have learned.the following frontmy review of emails,
bank records, and other documents:

a. On or about August 2, 2013, ASHE, YAN, and PIAO
arranged.tolhave?dinner?at aimestaurant_in New York, New'York. Later
that same night, ASHE sent YAN and PIAO two emails, one titled 
Banking Info? and the other titled ?Personal Banking Info,? which
respectively contained the account information for PGA
Account?2 and one of his personal bank accounts jointly held with
his wife. In response to personal bank account information,
PZAO replied to ASHE and YAN, ?Will get on it right away.?

25

 

 

b. On Saturday,.August 3, 2013, PIAO sent another reply
to ASHE and YAN to email with his personal bank account
information stating, ?it is done. Waiting to score.?

c. On.or about.August.5, 2013, joint bank.account
with his wife received a wire of $19,975 from a company associated
with.YAN and PIAO. .ASHE replied on.Monday morning, August 5, 2013,
?Wish to confirm receipt of US $19,975.00 today to my personal bank
account and to thank you profusely for delivering on your promise
re. the same. Grateful if you could provide me with a bit of info
on the body on which I have been designated to serve as Honorary
Chairman.? PIAO replied ?Glad.that we finally are able to implement
our good will, this is just a start and told ASHE that they would
provide him with the information about the organization for which
he would be ?Honorary Chairman.? Following the initial payment to
ASEfiin August 2013, YAA?and.PIAOIbegan paying ASHE $19,975 per month
for his purported role as ?Honorary Chairman? of which is an
organization run by YAN and PIAO supposedly to promote suStainable
global development.

YAN and PIAO Arrange Additional Payments to ASHE in Exchange For
Official Actions On Behalf of a Chinese Security Company

48. Defendant JOHN W. ASHE formally assumed the role as the
68th President of UNGA in September 20l3. Based on my review of
emails, bank records, and other documents, I know that on.September
17, 2013, ASHE and the UN Secretary General hosted a reception to
mark the opening of the 68th Session of At request,
defendants SHIWEI YAN, a/k/a ?Sheri Yan,? HONG PIAO, a/k/a
?Heidi Park,? arranged for a Chinese security technology executive
to send wires of approximately $100,000 to PGA
Account?2, supposedly to reimburse ASHE for half the cost of the
reception. Approximately one month later, ASHE accompanied and
PIAO to Antiguaso that could seek to sell his product to Antiguan
officials. Specifically, I have learned the following:

a. On September 4, 2013, ASHE emailed.YAN and PIAO that
plans were ?well underway? for the September 1? reception, although
the Secretary General' office had asked ASHE to pay for the recept?iOn
in its entirety. ASHE told YAN and PIAO that he ?warmly welcome[d]
your generous offer to share half the cost of this reception with
me.?

b. On.September 12, 2013, PIA?)emailed ASHE, wittia.copy
to YAN, a list of attendees for the reception? The list included.YAN

26

and PIAO themselves CC-2 and another Chinese media executive . Next
to name PIAO noted that was the ?sponsor.?

c. On September 16, 201.3, PGA Account?2 received
three wires from a particular bank in China (the ?Chinese Bank?)
totaling approrimately $100,000. The memo for each of the wires
stated ?Beijing Sponsorship, and the memo for one particular wire,
in the amount of $9,985, specifically noted that it originated from
That morning, PKAO sent an email to ASHE, copying YAN, informing
ASHE that [o]ur office? had wired the funds from Beijing three days
earlier. ASHE emailed YAN and PIAO confirmation that he had received
the funds. Later that day, PIAO emailed ASHE, again copying YAN, and
told ASHE that PIAO, ASHE, and had ?a very pleasant visit to
your office this morning? and they were ?warmly received. PIAO added
that CCMZ had decided to visit to Antigua and that he had also wanted
to make a ?small contribution? the Prime Minister's upcoming trip
to New York for the UNGA meeting through ASHE. ASHE replied to PIAO,
?[llet me know what he has in mind re. the trip when we meet
tomorrow."

d. Approximately one month later, YAN and PIAO arranged
for PIAO, ASHE, and CC-2 to travel to Antigua together so that 
could meet Antiguan officials about a possible business deal. On
October 22, 2013 PEAO emailed ASHE and YAN and said that ?the purpose
of the visit to Antigua is about to ?help? a Chinese company [the
?Chinese Security Company?] to invest $20m in Antigua to build a
national internet security system.? Later that day, PIAO emailed
ASHE and YAN information about the Chinese Security Company and told
ASHE that their agenda for the trip was Meeting with the relevant
ministers to present the proposal 2. If your country is interested,
we would like have an one page meeting memo to show the interest from
your government. 3 . Invite Chinese Ambassador to have lunch or dinner
to brief him on this project, 4. Invite your country Ministers to
visit China and meet with the top leader of [The Chinese Security
Company] 

e. On October 22, 2013, ASHE emailed PIAO and YAN with
the subject line ?Trip to Antigua.? ASHE said that [t]he Minister
will be at the airport to meet you on arrival tomorrow. He is quite
keen to hear the proposal so his staff will take you to a nearby tech
facility so that you can make the presentation. See you onboard.
Cheers.? A few minutes later ASHE sent another email to PIAO and YAN
and stated [f3 orgot to add that, as a testament to your importance,
the Minister also wanted you to know that he would be available to
meet with at 10:00 am. on Wednesday, October 30, in Washington D.C.
for any follow?up discussions for tomorrow?s meeting.?

27

 

. On October 23 2013 ASHE and PIAO traveled to Antigua
from New York. flew to Antigua on or about the same date from
Beijing. .ASHE and PIAO subsequently returned to New York the
following day.

g. Following the trip to.Antigua,.ASHE also facilitated
a meeting between executives for Chinese Technology Company and
officials of Kenya, where the Chinese Technology Company was also
looking for business. On October 30, 2013, PIAO emailed ASHE with
a.copy to YAN, telling ASHE that was in Nairobi, Kenya, where
he would be joined.by other individuals from the Chinese Technology
Company, and that ?they hope you can arrange them to start meeting
with someone from the Ministry of Internal Affairs.? .ASHE replied
?Noted.? On November 3, 2013, PIAE?emailed ASHE, wittLa copy'to?TAN,
and said that even though had not yet received a call from a
particular senior Kenyan foreign.official, YAN and PIAO thanked for
ASHE for ?making such an effort? to set up the meeting for the Chinese
Technology Company since ?now [the Chinese Technology Company]
recognizes our strong government connection.?

h. Twotdays later, on November's, 2013, ASHE emailed.YAN
and PIAO: have been in touch with [a particular Kenyan UN official
(?Kenyan UN Officialfl?)] . . . and informed him of your desire to
meet with him when he in Beijing . He has agreed and will be providing
me with.his contact details once he gets there on Thursday. Once he
does, I will forward you the same so you (and/or the [Chinese Security
Company] reps) can meet with him. BTW he has indicated that Kenyan? 
[sic] [senior intelligence official] is now keen to meet with the
[Chinese Security Company] reps when the latter return to Nairobi.?
On November 7, 2013, ASHE emailed YAN and PTAO that ?[Kenyan UN
H?uaChineseT?chnology
Company] reps on Saturday afternoon,? and 
the Kenyan SN Official?1?s contact information. .ASHE added ?[t]he
ball is now in your court but please let me know if anything is needed
from my end to make it happen.?

i. On November 9, 2013, YAN emailed ASHE that she had
?a very interesting dinner with [Kenyan UN Officialwl] and the,
conversation was productive. Later that day, ASHE told PIAO and YAN
that he had received an update on their meeting from Kenyan UN
Official?1 and.that Kenyan.UN<foicialm1 informed ASHE that he would
seek to make arrangements for the Chinese Technology Company ?to meet
with those who are best placed to make a decision.on the procurement
of the equipment . . . Later the same emailed YAN and
PIAO and asked for the dates for when the Chinese Security Company

28

individuals would next be in Kenya so that ASHE would be able to ?keep
the pressure up? on Kenyan UN Official-1.

I j. In December 2013, ASHE solicited $100,000 from PIAO
and YAN supposedly in order to pay for his staff?s holiday party.
On December 4, 2013, ASHE emailed YAN:

Re. the promised may I suggest the

following approach re. remitting it to me. if
the entire amount.is towbe sent in.one shot then
it?s best to send it to the PGA.account and then

any questions by the bank. This is my preferred
approach since that account has been used for
large amounts and would not raise any red flags.

lots of love

k. On.December 11, 2013, YAN?emailed ASHE that $100,000
was being sent tocnuaof the PGA Accounts. On December 12, 2013, PGA
Account?2 received a $100 000 wire from Individual?1 who, as described
above, is a United States?based business associate of YAN and PIAO,
who YAN'and PIAO have repeatedly asked.to wire money on their behalf
at times relevant to the Complaint.

1. On.December 23, 2013, ASHE arranged for a conference
call between executives from the Chinese Security Company and two
Antiguan.Ministers. After the call, PIAO emailed.ASHE, with.a copy
to KAN, and said.that during the Call the parties agreed.on.a further
schedule of meetings and visits after which they would sign a
memorandum of understanding and ?move forward according to
the implementation framework."

m. On.January 16, 2014, ASHE emailed.PIAO that he needed
some possible dates ?for the visit.by the [Chinese Security Company]
folks to visit Antigua, pronto. The plan.is to have them meet with
the Ministers and sign the MOUL The Prime Minister may also
participate in the meeting- depending on the date of the visit and
his schedule.?

n. On April 2, 2014, PEAO wrote ASHE and informed him
that the Chinese Security Company ?team? would be arriving in Antigua
on April 4, 2014. On April 6, 2014, ASHE emailed PEAO and YAN and
said that a senior.Antiguan national security minister had.told him

29

 

 

that he had met with the Chinese Security Company executives and that
the Minister had signed the final version of the MOU with the Chinese
Security Company. ASHE added ?Bottom line: there is now a signed MOU
between the Government of Antigua and Barbuda and [the Chinese
Security Company] . The subject line of email to YAN and PIAO
was ?Delivering on a promise."7

0. Based on my review of records for PGA Accounth, I
know that during the same period that ASHE was receiving payments
from CC-2, YAN, and PIAO to facilitate the Chinese Security' 5 Company
business interests in Antigua and elsewhere, ASHE sent the Prime
Minister himself approximately $170,000 from PGA Account-m2.

YAN and PIAO Arrange For a $200, 000 Payment to ASHE in Exchange For
Attending a Conference in China In Official Capacity

49 . I also know from review of emails that after defendant JOHN
W. ASHE became UNGA President, defendants SHIWEI YAN, a/k/a ?Sheri
Yan,? and HEIDI HONG PZAO, a/k/a ?Heidi Park,? also arranged for a
$200,000 payment to ASHE in exchange for ASHE making an official
appearance at a conference in China being organized by a Chinese real
estate developer . Specifically, from my review of emails,
bank documents, and other documents, I have learned the following:

a. On October 18, 2013, PIAO emailed ASHE, with a copy
to YAN, and told ASHE that PIAO and YAN had been working on obtaining
additional funds for ASHE . PIAO told ASHE that ?an old friend of Sheri
who is extremely wealthy? was organizing an international conference
in Guangzhou, China (the ?Guangzhou Conference?) and that PIAO and
YAN had suggested that ASHE be invited to the conference. PIAO
attached a program for the conference that listed several current
and former government officials as invited attendees, including ASHE .
ASHE replied that the Guangzhou Conference was ?very tempting indeed?
and that he might make it, but that his entire ?team? would need to
accompany him. YAN replied to ASHE that she had [j]nst talk[ed} to
Heidi, she is going to write to you. In short, all the people who
travel with you will be covered by the man and plus . PIAO then replied
to ASHE that are sure that he will cover the cost of your team, 
and requested information about team and travel??plan?s". 

 

7 The prior day, ASHE wrote YAN and PIAO and requested that they

secure ?the almost that ASHE supposedly needed to organize
a concert at the UN. ASHE also requested that the Chinese Security
Company pay for street lights and iPads for the Antiguan government.

30

b. On or about October 24, 2013, YAN emailed ASHE and
PIAO and stated ?[alccording to our strategy plan, office
emailed me the invitation to John this morning . . . I will ask $200, 000
for this trip. . . .A few minutes later, YAN emailed ASHE, with
a copy to PIAO, a draft invitation from to ASHE to attend the
Guangzhou Conference. YAN told ASHE that the invitation had been
approved by and YAN added that you may see that I purposely
add some words on.future relationship between.you and.him, that will
establish a good platform for you today and tomorrow.? The draft
invitation was addressed from to ASHE as UNGA President and,
in addition to inviting ASHE to the Guangzhou Conference, stated
that, ?After attending this Summit, 1 wish that you would remember
that you have a sincere friend in Guangdong Province the economic
powerhouse in China. And your friend here has the pleasure to offer
you a permanent convention venue for the UN meetings on the
sustainability and climate changes in the efforts to fully realize
the Millennium Development Goals, as well as for the 193 members of
the UN to convene for multilateral discussions on the tOpics of
priority concerns."

c. On October 27, 2013, PIAO emailed ASHE and YAN and
told.ASHE that ?in order to have to wire the money to 6831SGA
account, we suggest that you write a courtesy letter (in 6am PGA
letterhead) to to accept his invitation, and in the letter
also list out the name and.title for all the people to be travelling
with you, in order to make the logistic arrangement for them.? The
next day, ASHE emailed the ?courtesy letter? to suggested by
PIAO. The letter was addressed.to and was on official
UNGA President letterhead. In the letter, ASHE told he was
pleased to accept invitation to him and his team to attend
the Guangzhou Conference. ASHE stated that at the conference ASHE
would ?deliver a statement on the topic of Identifying the Parameters
of the Postw2015 Development Agenda.?? .ASHE then listed four UN
officials that would attend the conference with him and asked 
to contact his special assistant to ?finalize the logistical
arrangements.?

d. On October 29, 2013, PIAO emailed ASHE and YAN and
told.ASHE that ?in order to get the funding wired PIAO and
YAN recommended that instead of asking to contact special
assistant to make the ?logistical arrangements,? that ASHE revise
his letter to to ask that the arrangements be made through.YAN.
Later that day, PIAO emailed ASHE again, copying YAN, asking ASHE:
?As for the from which account would you like it to
be wired to? The 68 Please advise.? ASHE replied to PIAO and

31

 

 

YAN'that the money should be wired to the ?PGA.account" and.attached
a revised letter to In the revised letter, ASHE told CC-3 to
have his staff ?contact my.Adviser on Economic Matters, Ms. Shiwei
Yan, to finalize the logistical arrangements for the trip."

e. Later that same day, ASHE sent two ?letters of
appointment? to YAN and PIAO, which were back?dated to the prior month,
September 2013.' In one letter, on UNGA President letterhead, ASHE
informed each of YAN and PIAO that they had each been appointed
?Adviser, Economic Matters" office. In the other letter,
on Antiguan government letterhead, ASHE informed YAN and PIAO that
they had each been appointed as ?Adviser to Office of the Prime
investments
in Antigua and Barbuda from the entire Asia region.? In the email
enclosing the letters, ASHE stated, believe these complete the
outstanding requests that were made to me.?8

E. On November 3, 2013, YAN emailed ASHE, with a copy
to PIAO, telling ASHE that ?Guangzhou has been wired 200k to PGA office
today? and that ?25k? had been wired to travel agent . YAN also
asked for the name of UN security personnel who would be traveling
with.ASHE to the Guangzhou Conference. On November 4, 2013, 
PGA Aoccountm2 received a $200, 000 wire from China from one of 
companies. That morning ASH?iemailed KAN: of
$200k to the 

g. On November 17, 2013, ASHE attended the Guangzhou
Conference. According to the agenda for the conference, ASHE gave
a Speech to the conference and then gave media interviews on global
economic development. 

 

8 Based on my discussions with the Department of State, I

understand that YAN and PIAO, who are naturalized United States
citizens, were later accredited as diplomatic advisers for the period
between September 2013 and September 20l4, based on these backdated
appointments by ASHE . At most YAN and PIAO accordingly have residual
official act immunity during this time period? As'described above
and below, YAN and PIAO facilitated the bribes to ASHE in their
personal capacities, and as executives of seeking the
diplomatic status conferred by ASHE simply as a way to expedite bribe
payments and, in any event, many of their actions predated September
2013.

32

LAUNDERING OF BRIBERY FUNDS

 

50. Based on my review of bank records and other documents,
I know that payments described above facilitated by defendants SHIWEI
YAN, a/k/a ?Sheri Yan,? and HEIDI HUNG PIAO, a/k/a ?Heidi Park,? to
defendant JOHN W. ASHE were transmitted from China as part of the
scheme to promote the bribery of the Antiguan Prime Minister detailed
above, and that steps were taken to conceal the source and nature
of the payments.9 For example:

a. The $300,000 payment by to ASHE in July 2012 to
PGA.Account?1, which was facilitated by IAN and PIAO, a/k/a ?Heidi
Park,? in exchange for ASHE advocating for the business interests
of to the Prime Minister, was sent by wire from Individualwl?s
domestic bank account after which IAN and PIAO reimbursed
Individual?1? bank account in China. As noted above, approximately
$100,000 was then sent to the Prime Minister in Antigua from PGA
Account?l.

b. The $100, 000 payment by CC-2 to ASHE in September 2013
to PGA.Account-2, which was facilitated by IAN and PIAO in exchange
for ASHE advocating for the business interests of the Chinese Security
Company in Antigua, was sent by wires from the Chinese Bank in China.
As noted above, approximately $170, 000 was sent to the Prime Minister
in Antigua from PGA Account?2, including $20,000 during the month
after wired $100,000 to the account.

FAILURE TO FULLY REPORT HIS INCOME TO THE IRS

51. Based.on my review of the IRS Forms 1040 jointly filed.by
defendant JOHN W. ASHE, and his wife, a United States citizen, for
tax years 2013 and 2014, I know that ASHE failed to report income
sufficient to account for his payments from, among other things:
his self?described salary as UNGA President; (ii) his
and his wife?s payments from defendants NG LAP SENS, a/k/a
?David Ng,? FRANCIS LORENZO, and JEFF C. YIN, a/k/a ?Yin Chuan,?
through and and his payments from
defendants SHIWEI YAN, a/k/a ?Sheri?Yan,? HONG4PIAO, a/k/a
?Heidi Park,? through.NGO~2. Specifically, I learned.the following
from my review of tax returns and my review of bank records:

 

9 From my review of documents, I know that bribery of a public

official is illegal in Antigua under the Prevention of Corruption
Act, which was enacted by the Antiguan Parliament on November 5 2004 .

33

 

 

a. CHIC: about.April 15, 2014, ASHE and.his wife jointly
filed their Form 1040 for tax year 2013. .ASHE reported his total
income as $220,500 and his wifefs income as $30,000, which ASHE
declared was true and correct under the penalty of perjury. In fact,
I know based on bank records, that during 2013, ASHE was paid
approximately $810,000 from the following sources: $274,881.03
by the Government of Antigua Barbuda; (ii) $25,000 by 
$119,850 by (iv) $90,000 by and at least
$300,000 in what ASHE described as ?salary? payments and alleged
reimbursements from PGA Account?2, which was funded in large part
by bribe payments, as described above. In total, ASHE and.his wife
underreported their income by at least approximately $4 62 350 . 00 for
year 2013.

b. Chlor'about.April 15, 2015, ASHE and.his wife jointly
filed their Form 1040 for tax year 2014 . Just as the prior year, ASHE
again reported his total income as $220,500 and his wife?s inCOme
as $30 000 which ASHE declared was true and correct under the penalty
of perjury. In fact, I know based on bank records, that during 2014,
ASHE was paid approximately $1,050,000 from the following sources:
$179,562.09 by the Government of.Antigua aIBarbuda; (ii) $69,925
$120,000 and (iv) at least $678,904.28 in
what.ASHE described as ?salary? payments and alleged.reimbursements
from PGA Account?2, which was funded in large part by bribe payments,
as described.above. his wife under reported.their
income by at least approximately $796,329.28 for year 2014.

52 . Based on my review of emails between defendant JOHN W. ASHE,
his wife, and.a friend, who works as an accountant and assisted ASHE
and his wife to prepare their tax returns in various years, including
in_calendar years 2013, 2014, and 2015 (the ?Accountant"), and.my
conversations with the Accountant, 1 have learned the following:

a. In or about Spring 2013, in connection with the
preparation of federal tax return for tax year 2012, the
Accountant had conversations with.ASHE and his wife concerning the
existence of PGA Account~l? She Accountant understood that PGA
Account?1 account was used for URGA Presidency: The
Accountant was_not told that ASHE had transferred funds.from PGA.
Account-1 to perSonal accounts or used such funds to pay for personal
expenditures.

b. Also in or about Spring 2013, in connection.with the
preparation of federal tax return for tax year 2012, the
Accountant was presented with a Schedule (Profit or Loss from
Business) for PGA Account?1, containing certain.amOunts. A.few'days

34

later, the Accountant was given another Schedule C, also for tax year
2012, by ASHE and his wife, with different figures . Neither ASHE nor
ASHE's wife provided.a basis for the changed figures. .ASHE and his
wife requested that the Accountant adjust the gross receipts and
expenditures reported for PGA Account?1 so that the net profit
reported was zero. The.Accountant, who acceded.to this request, was
not provided with documentation supporting the request.

. In or about Spring 201.4 the Accountant again assisted
ASHE and his wife to prepare their federal tax return, for tax year
2013. Neither ASHE nor his wife informed the Accountant that ASHE
had.opened PGA.Accountm2 and had transferred funds from it into one
or'more personal accounts. As they had the prior year, ASHE and his
wife provided the Accountant with certain figures of income and
expenses, and then changed those figures, without explanation or
documentation. For example:

i. On.March 25, 2014, wife sent an email to
the Accountant, copying ASHE, and told the Accountant that, with
respect to the reporting of income, ?it should be increased
from last year but not by too much,? even though ASHE's income had
increased by approximately $500,000 since the prior tax year.

ii. On April 1, 2014, ASHE's wife sent a draft tax
return to ASHE and the Accountant, which reflected a gross income

income), and told.ASHE to ?please reflect on gross income amount,?
because ?as it stands we owe a sizable amount now.? One week later,
wife sent ASHE their final tax return (the same return they
filed with the IRS) which reduced their gross income to approximately
$161,000, even.less than their already significantly underreported
income in the draft tax return.

d. In or about Spring 2015 the Accountant again assisted
ASHE and his wife to prepare their federal tax return, for tax year
2014. Neither ASHE nor his wife informed the Accountant that ASHE
still had PGA Account~2 and had transferred funds from it into one
or more personal accounts.

e. The Accountant never informed ASHE or his wife that
income ASHE received was tax?exempt by virtue of his position or that
ASHE did not need to report income he received. On the contrary, the
Accountant informed ASHE and.his wife that they needed.to report all
income.

35

 

 

. Although the Accountant prepared returns for ASHE and
his wife in.calendar'years 2013, 2014, and 2015 (for tax years 2012,
2013, and 2014), ASHE and his wife filed the returns with the IRS
themselves. -

53. Basedcx1nw'reviemrof bank.records and.credit card.records
for defendant and his wife, I know that during the years
that ASHE and his wife were significantly underreporting 
income, ASHE and his wife made several expensive purchases, such as
the following:

a. In 2013 and 2014, ASHE repeatedly ordered expensive
handmtailored suits and clothing from a company in Hong Kong (the
?Clothing Company?). For example, in June 2014, ASHE had total
charges from the Clothing Company in the amOunt of approximately
$59,000.

b. In.or about July 2013, purchased
a membership to a luxury vacation club in South Carolina for
approximately $69,000.

c. On or about March 16, 2014, ASHE and/or his wife
purchased two Rolex watches for approximately $54,000.

d. In or about September 2014, ASHE paid 24 months of
the lease of a new BMW X5, paying approximately $40,000.

7 e. Between in or about October 2013 and March 2014, ASHE
and/or his wife made approximately six purchases from Gucci stores
totaling more than $5,000.

WHEREFORE, deponent respectfully requests that warrants be
issued for the arrest of ASHE, FRANCIS LORENZO, SHIWEI YAN,
a/k/a ?Sheri Yan,? and HEIDI SONG PIAO, a/k/a ?Heidi Park,? the
defendants, and that they be imprisoned or bailed, as the case may
be, and that NO LAP SENS, a/k/a ?David Ng,? and JEFF C. YIN, a/k/a

36

?Yin Chuan,? the defendants, be imprisoned or bailed, as the case

may be.
Ow,

JAsoq P. ALBERTS
Special Agent
Federal Bureau of Investigation

Sworn to before me this
5th day of October, 2015

xi 
THE B. PITMAN

UNITED STATES yebr TRATE JUDGE
SOUTHERN CT OF NEW YORK

a

I 

37