Case 6:18-cr-00067-AA Document 1 Filed 02/21/18 Page 1 of 5 FILED 21 FEB' 1812:441.SDC·I»: UNITED STATES DISTRICT COURT DISTRICT OF OREGON EUGENE DIVISION UNITED STATES OF AMERICA 6:18-CR- v. ~l · AA INDICTMENT 18 U.S.C. §§ 1343 and 1957 RODNEY PAUL GREGORY, Defendant. Forfeiture Allegation THE GRAND JURY CHARGES: COUNTS1THROUGH3 (Wire Fraud) (18 u.s.c. § 1343) 1. Beginning no later than May 201 7 and continuing through the present, in the District of Oregon and elsewhere, defendant RODNEY PAUL GREGORY devised and intended to devise a scheme and artifice to defraud and to obtain monies by means of false and fraudulent pretenses, representations, and promises, and during such period stated above, executed and attempted to execute such scheme and artifice and, in so doing, transmitted and caused to be transmitted in interstate and foreign commerce, by means of wire communications, certain electronic sounds, signals and writings, such scheme and artifice and wire communications being more fully and specifically set forth below. Revised 03/2017 Case 6:18-cr-00067-AA Document 1 Filed 02/21/18 Page 2 of 5 MANNER AND MEANS AND SCHEME TO DEFRAUD 2. GREGORY used the following manner and means to carry out the material scheme and artifice to defraud: 3. Unknown co-conspirators would target individuals through online dating websites with various romance scams. The unknown co-conspirators would impersonate military or civilian personnel working overseas, feigning the need for funds to help with foreign taxes, travel costs, or other false representations. Based on the co-conspirators false statements and concealments, the individuals parted with their money. 4. GREGORY incorporated companies and opened numerous business bank accounts in order to receive wires and other deposits from victims of the online romance scams. 5. GREGORY would provide the banks false information regarding the businesses, including the businesses' primary business activity. 6. Victims, following the directions of the unknown co-conspirators, would wire or otherwise deposit money to the accounts set up by GREGORY. 7. Upon receipt of the money into the bank account, GREGORY would wire the money to overseas bank accounts. 8. On May 11, 2017, federal agents interviewed GREGORY regarding the actions listed above. GREGORY claimed that he would receive instructions regarding setting up bank accounts and companies from a woman he met through an online dating website. 9. Agents informed GREGORY that the thousands of dollars he was receiving and transferring out of the country were proceeds of fraud. GREGORY claimed he was not aware that the funds wired to the accounts were proceeds of fraud, and that he did the work as a result of promises of love from the woman he met on the online dating website. INDICTMENT Page 2 Case 6:18-cr-00067-AA 10. Document 1 Filed 02/21/18 Page 3 of 5 Agents informed GREGORY that his actions could constitute wire fraud and money laundering. GREGORY acknowledged that he understood. 11. Following the May 11, 2017 interview, GREGORY continued to open new business bank accounts using fraudulent information. 12. Following the May 11, 2017 interview, GREGORY continued to receive wire transfers from victims of fraud into these and other business bank accounts he established, and GREGORY continued to wire money from the business bank accounts to international bank accounts, including accounts in China. 13. Between May 11, 2017 and the end of August 2017, GREGORY either transferred or withdrew over $200,000. WIRE COMMUNICATIONS 14. On or about the dates set forth below in each Count, in the District of Oregon and elsewhere, GREGORY, for purposes of attempting to execute and executing the abovedescribed material scheme and artifice to defraud and for obtaining money and property by means of materially false and fraudulent pretenses, representations, promises, and omissions of material facts, knowingly caused the following communications via interstate wire: COUNT DATE 1 May 26, 2017 2 June 29, 2017 3 August 17, 2017 DESCRIPTION OF EXECUTION A $20,000 transfer via interstate wire from victim A.K. to GREGORY'S account at Banner Bank. A $6,000 transfer via interstate wire from victim G.W. to GREGORY'S account at Red Canoe Credit Union. A $30,000 transfer via interstate wire from victim R.S. to GREGORY'S account at Maps Credit Union. All in violation of 18 U.S.C. § 1343. INDICTMENT Page3 Case 6:18-cr-00067-AA Document 1 Filed 02/21/18 Page 4 of 5 COUNT4 (Money Laundering) (18 u.s.c. § 1957) 15. Paragraphs 1 through 14 are re-alleged and incorporated herein. 16. As set forth below, in the District of Oregon and elsewhere, defendant RODNEY PAUL GREGORY knowingly engaged in and attempted to engage in a monetary transaction, by, through, and to a financial institution, in and affecting interstate commerce, in criminally derived property that was of a value greater than $10,000 and was derived from a specified unlawful activity (wire fraud): COUNT 4 MONETARY TRANSACTION On or about May 31, 2017, GREGORY caused $78,000 to be transferred from his Banner Bank account to an account at the Agricultural Bank of China. In violation of 18 U.S.C. § 1957. FORFEITURE ALLEGATION Upon conviction of the offenses alleged in Counts 1 through 4 of this indictment, RODNEY PAUL GREGORY shall forfeit to the United States, pursuant to Title 18, United States Code, Sections 981(a)(l)(C), 982(a)(2), and Title 28, United States Code, Section 2461(c), any property, real or personal, which constitutes or is derived from proceeds traceable to the violations. If any of the above-described forfeitable property, as a result of any act or omission of GREGORY: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third party; (c) has been placed beyond the jurisdiction of the court; INDICTMENT Page4 Case 6:18-cr-00067-AA Document 1 Filed 02/21/18 Page 5 of 5 (d) has been substantially diminished in value; or (e) has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) as incorporated by Title 18, United States Code, Section 982(b ), to seek forfeiture of any other property of GREGORY up to the value of the forfeitable property described above. Dated this 2{ day of February 2018. A TRUE BILL. Presented by: BILLY J. WILLIAMS United States Attorney -/or~~ Assistant United States Attorney INDICTMENT Page 5