Case 1:17-cr-00102-MHC Document 1 Filed 03/14/17 Page 1 of 3

iblNAL
I N THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
A T L A N T A DIVISION

U N I T E D S T A T E S OF A M E R I C A

V.
MARK VARTANYAN, A / K / A

Criminal Information
No. 1:17-CR-102

"KOLYPTO"

THE UNITED STATES ATTORNEY CHARGES THAT:
COUNT ONE
Computer Fraud
1. The Defendant, M A R K V A R T A N Y A N , is a Russian citizen who is
known to have used the alias "Kolypto". V A R T A N Y A N resided i n both Ukraine
and Norway during the period relevant to this Information.
2. "Citadel" is a malware toolkit designed to infect computer systems and
steal financial account credentials and personally identifiable information f r o m
victim computer networks. Beginning i n or about 2011, Citadel was offered for
sale on invite-only, Russian-language internet forums frequented by
cybercriminals. Users of Citadel targeted and exploited the computer networks
of major financial and government institutions around the w o r l d , including
several financial institutions i n the United States. According to industry
estimates. Citadel infected approximately 11 million computers worldwide and
is responsible for over $500 million i n losses.

 Case 1:17-cr-00102-MHC Document 1 Filed 03/14/17 Page 2 of 3

3. Between on or about August 21, 2012 and January 9, 2013, while
residing i n Ukraine, and again between on or about A p r i l 9, 2014 and June 2,
2014, while residing i n Norway, V A R T A N Y A N engaged i n the development,
improvement, maintenance and distribution of Citadel. During the abovereferenced periods, V A R T A N Y A N uploaded numerous electronic files that
consisted of Citadel malware. Citadel components. Citadel updates and patches,
and Citadel customer information, all w i t h the intent of improving Citadel's
illicit functionality.
4. O n or about November 6, 2012, i n the Northern District of
Georgia and elsewhere, the defendant, M A R K V A R T A N Y A N , aided and abetted
by others known and unknown to the United States Attorney, knowingly caused
and would, if completed, have caused the transmission of a program,
information, code, and command, and, as a result of such conduct, intentionally
caused damage without authorization to a protected computer, specifically, loss
to a person and persons during a 1-year period f r o m V A R T A N Y A N ' s course of
conduct affecting protected computers aggregating at least $5,000 i n value, and
damage affecting 10 or more protected computers during a 1-year period.

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 Case 1:17-cr-00102-MHC Document 1 Filed 03/14/17 Page 3 of 3

A l l in violation of Title 18, United States Code, Sections 1030(a)(5)(A) and
(c)(4)(B), and 2.

J O H N A. H O R N

United States Attorney yf
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STEVEN D . GRIMBERG

Assistant United States
Georgia Bar No. 312144

Attorney

600 U.S. Courthouse
75 Ted Turner Drive S W
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181

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