Case Document 1 Filed 08/14/17 Page 1 of 7 A0 257 (Rev. 6/78) DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION - IN US. DISTRICT COURT BY: COMPLAINT INFORMATION CI INDICTMENT CI SUPERSEDING OFFENSE CHARGED 18 Laundering Petty Minor Misde- meanor Felony PENALTY: Not more than 10 years imprisonment; Not more than $250,000 ?ne; Not more than 3 years Supervised Release; and $100 Special Assessment Name of District Court. [Ma?ycation NORTHERN DIST NIA SAN . I, DEFENDANT - u.s SUSAN Y. soc-rte CLERK. us. . SHAUN W- NORTHERN DISTRICT or DISTRICT COURT NUMBER (3317 _9448 DEFENDANT PROCEEDING Name of Complaintant Agency, or Person Title, if any) FEDERAL BUREAU OF INVESTIGATION person is awaiting trial in another Federal or State Court, El give name Of court this person/proceeding is transferred from another district CI per (circle one) 20, 21. or 40. Show District this is a reprosecution of charges previously dismissed which were dismissed on motion SHOW of: DOCKET NO. US. ATTORNEY El DEFENSE this prosecution relates to a pending case involving this same defendant MAGISTRATE prior proceedings or appearance(s) before US. Magistrate regarding this defendant were recorded under CASE NO. Name and Of?ce of Person Furnishing Information on this form BRIAN J. STRETCH US. Attorney [1 Other US. Agency Name of Assistant US. Attorney (if assigned) WILLIAM FRENTZEN PROCESS: SUMMONS NO WARRANT If Summons, complete following: Arraignment Initial Appearance Defendant Address: Comments: IS NOTIN CUSTODY Has not been arrested, pending outcome this proceeding. 1) if not detained give date any prior summons was served on above charges 2) is a Fugitive 3) Is on Ball or Release from (show District) IS IN CUSTODY 4) On this charge 5) On another conviction Federal State 6) Awaiting trial on other charges If answer to (6) is "Yes", show name of institution If "Yes" give date ?led Month/Day/Year Has detainer Yes been ?led? No DATE OF . ARREST if Arresting Agency Warrant were not DATE TRANSFERRED Month/Day/Year TO U.S. CUSTODY ADDITIONAL INFORMATION OR COMMENTS Date/Time: This report amends A0 257 previously submitted Bail Amount: Where defendant previoust apprehended on complaint, no new summons or warrant needed, since Magistrate has scheduled arraignment Before Judge: 24 25 26 27 28 Case Document 1 Filed 08/14/17 Page 2 of 7 BRIAN J. STRETCH (CABN 163973) United States Attorney AUG 1 4 2017 ANNALOU TIROL Acting Chief, Public Integrity Section SUSAN Y. SOONG CLERK, U.S. DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SH SAN FRANCISCO DIVISION UNITED STATES OF AMERICA, CRIMINAL NO. . v. INFORMATION SHAUN W. BRIDGES, VIOLATIONS - 18 U.S.C. 1957 Money Laundering; Defendant. 982(a)(1) Forfeiture. I IN A I The United States Attorney charges: INTRODUCTORY ALLEGATIONS At all times relevant to this Information: 1. Defendant SHAUN W. BRIDGES (hereafter was a Special Agent with the United States Secret Service (hereafter assigned to the Baltimore Silk Road Task Force. Case Document 1 Filed 08/14/17 Page 3 of 7 2. Silk Road was a website where illegal goods were posted for sale, including narcotics. Silk Road was only accessible through The Onion Router, or network, a network designed to conceal the true IP addresses of computers on the network and the users? identities. The only accepted form of payment on Silk Road was Bitcoin. 3. Bitcoin was a form of digital currency that existed online. The value of Bitcoin ?uctuated widely from 2013 up to the present. 4. The Baltimore Silk Road Task Force was a task force formed jointly by several different federal law enforcement agencies, including designed to investigate and apprehend vendors, buyers, administrators, and the manager of Silk Road, including the head of Silk Road, R.U., a/k/a ?Dread Pirate Roberts,? a/k/a (hereafter 5. BRIDGES was assigned to, among other responsibilities, forensic computer investigations in an effort to locate, identify, and prosecute targets of the Baltimore Silk Road Task Force, including R.U., and other vendors, buyers, and administrators on Silk Road. Among responsibilities as a Special Agent with he served as an af?ant on warrants to seize assets, including digital currency. 6. Carl M. Force, IV, (hereafter ?Force?) was a Special Agent with the Drug Enforcement Administration. Force was assigned to the Baltimore Silk Road Task Force. Force was assigned to act in an undercover capacity in an effort to locate, identify, and prosecute targets of the Baltimore Silk Road Task Force, including R.U., and other vendors, buyers, and administrators on Silk Road. 7. On or about January 25, 2013, BRIDGES accessed Silk Road through a computer utilizing access obtained from an administrator on Silk Road. BRIDGES reset passwords and pins of various accounts on Silk Road and moved bitcoin from those accounts into a wallet that BRIDGES controlled. In this manner, BRIDGES fraudulently moved and stole approximately 20,000 bitcoin from Silk Road and Silk Road accounts. On or about January 26, 2013, BRIDGES moved those stolen bitcoin into an account at Mt. Gox, an online digital currency exchange based in Japan. On or about February 22, 2013, BRIDGES opened a personal investment account at Fidelity. On or between March CRIMINAL INFORMATION CR Case Document 1 Filed 08/14/17 Page 4 of 7 6, 2013, and May 7, 2013, BRIDGES laundered bitcoin in the Mt. Gox account, proceeds of the Silk Road fraud, into US. Currency and transferred the US. Currency into his Fidelity account. 8. In November of 2014, as part of his duties as a Special Agent with BRIDGES worked with the United States Attomey?s Of?ce in Baltimore, Maryland, to obtain a seizure warrant for bitcoin held by a digital currency exchange called Bitstamp. The seizure warrant authorized seizure of, among other things, approximately 1606.6488 bitcoin in various accounts at Bitstamp. The stated basis of the seizure warrant was that the account owners had not provided basic account holder information such as nanIe, address, and phone number. BRIDGES swore to the accuracy of the warrant as the af?ant. The warrant was executed on or about November 18, 2014. 9. In order to execute the warrant, in compliance with the warrant, and at direction, Bitstamp sent the seized funds to an online digital wallet created by BRIDGES. Only BRIDGES had the private key to access the funds in the digital wallet. 10. Among the accounts seized from Bitstamp, was an account owned and controlled by Force, that held bitcoin obtained from Force?s illegal activities while investigating Silk. Road. 11. On or about March 18, 2015, placed BRIDGES on administrative leave. On or about March 18, 2015, BRIDGES resigned from When BRIDGES left he retained the private key to access the funds that he had seized from Bitstamp. On or about March 25, 2015, BRIDGES was charged with criminal activity in the Northern District of California for his thefts from Silk Road. On or about June 15, 2015, BRIDGES signed an agreement with the United States Attomey?s Of?ce, Northern District of California, to plead guilty to money laundering and obstruction of justice stemming from the thefts from Silk Road. 12. On or about July 28, 2015, while on release from the pending case in the Northern District of California, BRIDGES caused transfer of the approximately 1606.6488 seized Bitstamp funds in the online wallet that belonged to the United States government into a separate online account at controlled by BRIDGES. is an online digital currency exchange. CRIMINAL INFORMATION CR U.) U1 6 is.) Case 3:17-cr-00448-RS Document 1 Filed 08/14/17 Page 5 of 7 13. Between July 28, 2015 and before going into custody, BRIDGES laundered the funds stolen from the United States government by moving the funds out of the account and into other various online wallets and accounts. COUNT ONE: (18 U.S.C. 1957 Money Laundering) THE MONEY LAUNDERING CHARGE 14. The allegations set forth in paragraphs 1 through 13 are hereby incorporated herein by reference as if set forth fully herein. 15. On or between July 28, 2015 and on or about November 15, 2015, in the Northern District ofCalifornia and elsewhere, the defendant, SI-IAUN W. BRIDGES. did knowingly engage and attempt to engage in the following monetary transactions by through or to a ?nancial institution. affecting interstate or foreign commerce, in criminally derived property ofa value greater than $10,000, that is the deposit, withdrawal, transfer, and exchange ofmonetary instruments, such property having been derived from a specified unlawful activity, that is. theft of government property, in violation of'fitle 18, United States Code, Section 641: Date Amount Description of Monetary Transaction 8/3/15 100 BTC :Nithtirawal from BTC-E account to online digital wallet 8/4/15 100 BTC from account to online digital wallet 8/5/15 100 BTC from account to online digital wallet 8/6/15 100 )Ii/iitigdrawal from account to online digital wallet 8/8/15 100 BTC Vi/liiliitlrawal from BTC-II account to online digital wallet 8/10/15 100 Eli/tii?hdrawal from account to online digital wallet 8/1 1/ 15 BTC Iii/tiifidrawal from account to online digital wallet 8/12/15 100 BTC Iii/tiilidrawal from account to online digital wallet 9/15/15 100 BTC \S/ifhiirawal from account to online digital wallet ?dWeQ? 4 CRIMINAL INFORMATION CR Case 3:17-cr-00448-RS Document 1 Filed 08/14/17 Page 100 BTC )?Nithdrawal from BTC-E account to online digital wallet 9/ 17/ 1 5 100 BTC EggiZZawal from BTC-E account to online digital wallet 9/18/15 100 BTC from account to online digital wallet 9/19/15 100 BTC llv/?iltild/Irc?wal from BTC-E account to online digital wallet 9/20/15 100 BTC from BTC-E account to online digital wallet 9/21/15 100 BTC ?gg?wal from BTC-E account to online digital wallet 9/23/15 100 BTC wafawal from BTC-E account to online digital wallet 9/24/15 6.6497 BTC ??grawal from BTC-E account to online digital wallet 11/16/15 605 BTC Se?dsit from multiple accounts into account ?suK7?at exchange Bit?nex Unknown 1037 BTC Deposit into hardware wallet All done in violation of Title 18, United States Code, Section 1957. FORFEITURE ALLEGATIONS: (18 U.S.C. 982(a)(1) Money Laundering Forfeiture) Upon conviction of the offense alleged in Count One of the Information, the defendant, SHAUN W. BRIDGES, shall forfeit to the United States, pursuant to 18 U.S.C 982(a)(1), any property, real or personal, involved in any such offense, or any property traceableto such property, including but not limited to the following: a money judgment equivalent to the amount of property involved in the violation of 18 U.S.C 1957: a. Any interest in, security of, claim against, or property or contractual rights of any kind in the goods or tangible items that were the subject of the violation; b. Any interest in, security of, claim against, or pr0perty or contractual rights of any kind in tangible property that was used in the export or attempt to export that was the subject of the violation; and c. Any property constituting, or derived from, any proceed obtained directly or indirectly as a result of the violation; and CRIMINAL INFORMATION CR Ix) Case Document 1 Filed 08/14/17 Page 7 of 7 d. Any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. If any ofthe property described above, as a result of any act or omission of the defendant: cannot be located upon the exercise ofdue diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond thejurisdiction ofthe court; has been substantially diminished in value; or (6) has been commingled with other property which cannot be divided without difficulty; the United States of America shall be entitled to forfeiture ofsubstitute property pursuant to 2i U.S.C. 853(p), incorporated by 18 U.S.C. 982(b)(l) and 28 U.S.C. ?2461(c). BRIAN J. STRETCH United States Attorney Mtg/?44M VALLIERE Chief, Criminal Division ANNALOU TIROL Acting Chief, Public Integrity Section (Approved as to form: f? AUSA WILLIAM FRENTZEN AUSA DAVID TRIAL ATTORNEY RICHARD EVANS CRIMINAL INFORMATION CR