Case 1:18-cr-00024-DLF *SEALED* Document 13 Filed 02/12/18 Page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STAIBS OF AMERICA
v.

Criminal No.:

F6 C(<_ ,z_,4,

Violation: 18 U.S.C. § 1028 (Identity Fraud)

RICHARD PINEDO,

Flt.ED
Defendant.

FEB 12 2018
Clerk, U.S. District and
Bankruptcy Courts

STATEMENT OF THE OFFENSE

Pursuant to Federal Rule of Criminal Procedure 11, the United States of America and the
defendant, RICHARD PINEDO, stipulate and agree that the following facts are true and accurate.
These facts do not constitute all of the facts known to the parties concerning the charged offense;
they are being submitted to demonstrate that sufficient facts exist that the defendant committed the
offense to which he is pleading guilty.
L

From approximately 2014 through December 2017, the defendant, RICHARD

PINEDO, operated an online service called "Auction Essistance." 1brough Auction Essistance,
Pinedo offered a variety of services designed to circumvent the security features of large online
digital payment companies, including a large digital payments company hereinafter referred to as
Company I.
2.

PINEDO sold bank accOlmt numbers through interstate and foreign comnerce,

specifically over the internet.

PINEDO obtained bank account numbers either by registering

accounts in his own name or by purchasing accounts in the names of other people through the
internet. Many of the bank accounts purchased by PINEDO over the internet were created using
stolen identities of U.S. persons. Although PINEDO was not directly involved in the registration

 Case 1:18-cr-00024-DLF *SEALED* Document 13 Filed 02/12/18 Page 2 of 4

of these accounts using stolen identities, he willfully and intentionally avoided learning about the
use of stolen identities.
3.

Company 1 required users to submit bank account m.unbers as a means of verifying

a user's identity. To circumvent this requirement, certain users (hereinafter "Users'') registered
for Company l's online services with bank account numbers in the names of other peo_ple.
PINEDO sold Users bank account numbers over the internet to aid and abet, and in connection
with, this scheme to defraud Company 1 by means of internet communications in interstate and
foreign connnerce.
4.

After acquiring bank account numbers from PINEDO, Users linked the bank

account numbers to their accounts with Company 1 as if they were the real owners of the bank
accounts. Company 1 sought to verify the bank account numbers by making de minimus trial
deposits into the accounts and asking Users to identity the amount of those trial deposits. PINEDO
told Users the amollllts of those trial deposits, thereby further aiding the Users in their scheme to
circumvent verification processes by Company 1.
5.

PINEDO frequently purchased bank account numbers from an individual he knew

to be outside the United States. Similarly, based on IP addresses and other information, PINEDO

knew that many of the persons to whom he sok:I bank account numbers were outside the United
States.
6.

In tota~ PINEDO knowingly transferred, possessed, and used, without lawfu I

authority, hundreds of bank account numbers to aid and abet, and in cormection with, the use of
the wires in interstate and foreign connnerce to defeat security measures employed by Company
l. PINEDO personally collected tens of thousands of dollars, and more than $ I ,000 during a one-

year period, through the sale of these bank account numbers.

2

 Case 1:18-cr-00024-DLF *SEALED* Document 13 Filed 02/12/18 Page 3 of 4

DEFENDANT'S ACCEPTANCE
The preceding statenent is a sur:rmary, made i>r th, purpose of providing the Court wtii

a &ctuaI basi, :tbr my guilty pb to the charge agaimt m:. It does mt n:Judc an oftbe facts
known to me regarding 11m oflcnsc. I make ~ statemmt k:nowiqpy and whmtarily ml
became I am, in met, guilty of the ~ charged. No threats have been made 1D m, nor am I
tnler the iaftueree of aeything that couki ~ e iey ability to uoderstam t1m Statement of the
Ofreme fully.
I have read every wont of this Staterrent oftbe Offense, or have bad it read to me.
Pursuant to Federal Rule of Criminal Procedure 11, after comulting with my attorneys, I agree
and stipulate 1o this Staten:att of the Oflcmet and declare ~er penalty of perjury tbat it is true
and correct.

Rchard
Dcdmlant

ATTORNEYS' ACKNOWLEDGMENT

coa:ur

I have read tlm Statenr:nt of~ O.freme, a.al haw reviewed it with my client ·fi.uly. I
in my client's desire to adopt am stipulate to this Statcm:nt of1he Oflimse as true em

accurate.

Date:

2.. { z..._

/t ~

 I

•

I

~

Case 1:18-cr-00024-DLF *SEALED* Document 13 Filed 02/12/18 Page 4 of 4

ROBERT S. MUELLER, III
Special Counsel
By:
Je ie S. Rhee
Se ior Assistant Special Counsel

L. Rush Atkinson
Ryan K. Dickey
Assistant Special Counsels
The Special Counsel's Office

4