Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 1 of 25

Approved:

@

NEGAR TEKEEI

/' 4

,
.
'

SXMSON ENZER

Assistant United States Attorneys
Before :

HONORABLE JAMES L . COTT

United States Magistrate Judge
Southern District of New York

SERT.ED COMPT,AINT
UNITED STATES OF AMERICA

Violations of

15 U.S.C. 5$ 701(b), 78ff;

17 C.F.R . 55 240.10b-57 18
U .S.C . 55 371, 1343, 1349

SOHRAB SHARMA,

a/k/a uSam Sharma,'' and

and 2

Robert Farkas,

a/k/a nBob ''

COUNTY OF OFFENSES :
New York

De fendants .

OUR CA SE NO .l8 -6165-MJ -HUN T
SOUTHERN DISTRICT OF NEW YORK ,

BRANDON RACZ, being duly sworn, deposes and says that he is
a Special Agent with the Federal Bureau of Investigation (nFBI'')
and charges as follows:
COUNT ONE

(Conspiracy To Comm4t securities Fraud)
1. From at least in or about July 2017, up to and
including the date of this Complaint, in the Southern District

of New York and elsewhere, SOHRAB SHARMA, a/k/a nSam Sharma,''
and ROBERT FARKAS, a/k/a ''Bobz' the defendants, and others known
and unknown, willfully and knowingly did combine, conspire,
confederate? and agree together and with each other to commit
offenses against the United States, to wit, securities fraudz in

violation of Title 15, United States Code, Sections 78j(b) and
78ff , and Title l7 , Code of Federal Regulations , Section
2 40 .105-5 .

2.

It was a part and object of the conspiracy that SOHRAB

SHARMA, a/k/a nSam Sharma,/' and ROBERT FARKAS, a/k/a ''Bobz'' the
defendants, and others known and unknown, willfully and

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 2 of 25

knowingly, directly and indirectly, by use of the means and
instrumentalities of interstate commerce and of the mails, and
of the facilities of national securities exchanges, would and
did use and employ manipulative and deceptive devices and
contrivances in connection with the purchase and sale of
securities, in violation of Title 17? Code of Federal

Regulations, Section 210.1Ob-5, by (a) employing devices,
schemes, and artifices to defraud; (b) making untrue statements
of material fact and omitting to state material facts necessary
in order to make the statem ents m ade, in the ligh t of the
circumstances under which they were made, not misleading; and

(c) enqaging in acts, practices, and courses of business which
operated and would operate as a fraud and deceit upon persons,

in violation of Title 15, United States Code, Sections 78j(b)
and 78ff, to wit, the defendants and others known and unknown
participated in a scheme to defraud purchasers of Centra Tech,

Inc. (ncentra Tech'') cryptocurrencies by making material
misrepresentations about Centra Tech? its purported partnerships
with Bancorp, Visa and Mastercard, its products, its licensing
in various states, and its executive personnel, causing

investors to purchase more than $25 million worth of Centra Tech
cryptocurrencies, which function as unregistered securities,
during the time period of Centra Tech's initial coin offering.
Overt A cts

3.

In furtherance of the conspiracy and to effect its

illegal object, SOHRAB SHARMA, a/k/a ''Sam Sharma,'' and ROBERT
FARKAS, a/k/a nBoby'' the defendants/ and others known and
unknownz commmitted the following overt acts, among others,
the Southern District of New York and elsewhere :

a . On or about August 14? 2017, SHARMA, in an
interview by a cryptocurrency podcast, made material
misrepresentations about an initial coin offering for the
digital assets and cryptocurrency company Centra Tech, for which
he was a founder, President, and Chief Technology officer at
v arious times .
b.
On or about September 6, 2017, FARKAS , a ch ief
marketing officer for Centra Tech, sent an email to an
indiv idual at a m arketing company describing Centra Tech's

currency conversion capabilities as nallow ling) real time
conversion of al1 supported cyrptocurrencies to give the user
the ab ility to spend their assets in real tim e anywhere in the
world that accepts Visa or Mastercard .''

2

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c. On or about November 28/ 2017, FARKAS attended a
blockchain technology conference in New York City, New York, on
behalf of Centra Tech, a sponsor of the conference, for the
purpose of promoting Centra Tech and its products.

(Title 18, United States Code? Section 371.)
COUNT > 0

(Socurities Fraud)
4. From at least in or about July 2017, up to and
including the date of this Complaint, in the Southern District

of New York and elsewhere, SOHRAB SHARMA, a/k/a ''Sam Sharmap''
and ROBERT FARKAS, a/k/a ''Bobz'' the defendants, and others known
and unknown, willfully and knowingly, directly and indirectly,
by use of the means and instrumentalities of interstate commerce
and of the mails? and of the facilities of national securities
exchanges, used and employed manipulative and deceptive devices
and contrivances in connection with the purchase and sale of
securities in violation of Title 17, Code of Federal

Regulations, Section 240.10b-5, by (a) employing devices,
schemes, and artifices to defraud; (b) making untrue statements
of material fact and omitting to state material facts necessary
in order to make the statements made, in the light of the
circumstances under which they were made, not misleading; and

(c) engaging in acts? practices, and courses of business which
operated and would operate as a fraud and deceit upon persons,
to wit, the defendants and others known and unknown participated
in a scheme to defraud purchasers of Centra Tech
cryptocurrencies by making material misrepresentations about
Centra Tech, its purported partnerships with Bancorp , Visa and
Mastercard, its products, its licensing in various states, and
its executive personnel, causing investors to purchase more than

$25 million worth of Centra Tech cryptocurrencies, which
funetion as unregistered securities, during the time period of
Centra Tech's initial coin offering.

(Title 15, United States Code, Sections 78j(b) & 78ff;

Title 17, Code of Federal Regulations, Sections 240.10b-5; and

Title 18, United States Code, Seetion 2.)
COUNT THREE

(Conspiracy To Copo it Wire Fraud)
5. From at least in or about July 2017, up to and
including the date of this Complaint, in the Southern District

of New York and elsewhere, SOHRAB SHARMA , a/k/a ''Sam Sharma,''

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 4 of 25

and ROBERT FARKAS? a/k/a nBobz'' the defendants, and others known
and unknown, willfully and knowingly combined, conspired,
confederated/ and agreed together and with each other to commit
o ffenses against the United States , to wit , wire fraud, in
violation of Title 18, United States Code, Section 1343.

6. It was a part and an object of the conspiracy that
SOHRAB SHARMA, a/k/a nSam Sharmaz' and ROBERT FARKAS, a/k/a
''Bobz'' the defendants, willfully and knowingly, having devised
and intending to devise a scheme and artifice to defraud, and
for obtaining money and property by means of false and
fraudulent pretenses, representations, and promises, would
did transmit and cause to be transmitted by means of wire,
radio, and television communication in interstate and foreign
commerce, writings, signs, signals, pictures, and sounds for the
purpose of executing such scheme and artifice, in violation of
Title 18, United States Code, Section 1343, to wit, the
defendants and others known and unknown participated in a scheme
to defraud purchasers of Centra Tech cryptocurrencies by making
material misrepresentations about Centra Tech, its purported
p artnersh ips with Bancorp , Visa and Mastercard , its products ,
its licensing in various states, and its executive personnel.

(Title

United states code, section 1349.)
COUNT FOUR

(Wire Fraud)
7.
From at least in or about Ju ly 2017, up to and
including the date of this Complaint? in the Southern District

of New York and elsewhere, SOHRAB SHARMA, a/k/a nSam Sharmaz''
and ROBERT FARKAS, a/k/a ''Bobz'' the defendants, willfully and
knowingly, having devised and intending to devise a scheme and
artifice to defraud and for obtaining money and property by
means of false and fraudulent pretenses, representations, and
promises, and attempting to do so, did transmit and cause to be
transmitted by means of wire, radio, and television
communication in interstate and foreign commercer writings,
signs, signals, pictures, and sounds for the purpose of
executing such scheme and artificez to wit, the defendants and
others known and unknown participated in a scheme to defraud
purchasers of Centra Tech cryptocurren cies b y making material
misrepresentations ab out Centra Tech , its purported partnerships
with Bancorp , Visa and Mastercard, its productsz its licensing
in various states, and its executive personnel, and in the
course o f executing such schemez caused interstate and
international wires to be sent, including emails between New

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York, New York and Florida and a location outside of the United
States .

(Title 18z United States Code, Section 1343 and 2.)
The bases for my knowledge and for the foregoing
charges arez in part, as follows:
8. I have been a Special Agent with the FBI for
approximately two and a half years. I am currently assigned to a
squad that investigates white collar crimesr including complex

financial frauds and conduct within the regulatory jurisdiction
of the U .S. Securities and Exchange Commission (nSEC''). I have
participated in investigations of such offenses, and have made
and particjpated in arrests of individuals who have committed
such offenses.

9.
The information contained in this Complaint is based
upon my personal knowledge, as well as information obtained
during this investigation, directly or indirectly, from other
SO ur Ce S ,

including, but not limited to: (a) business records and

other documents p such as trading records, bank records,
telephone recorda, and records of electronic communications?

including text messages; (b) publicly available documents; (c)
conversations with, and reports of interviews with, non-law-

enforcement witnesses; (d) conversations with? and reports
prepared by, other agents; and (e) conversations with
representatives from the U.S. Securities and Exchange Commission
(nSEC''). Because this Complaint is being submitted for the
limited purpose of establishing probable cause, it does not
include a11 the facts that I have learned during the course of
my investigation. Where the contents of documents and the
actions and statements of and conversations with others are
reported herein? they are reported in substance and in part .
Where figures, calculations, and dates are set forth herein,
they are approximate, unless stated otherwise .
The Defendants and Relevant Entities
10. Based on my review of publicly available information
and records provided by Centra Tech to representatives of the
SEC, I have learned the following, in substance and in part:

a . Centra Tech is a Delaware corporation based in
Miami Beach, Florida. Centra Tech advertikes itself through its

website, https://centra .Lech (the ''Centra Tech Website?/)? press
releasesz and statements on the Internet as a company that

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 6 of 25

offers various methods to store and spend digital assets such as
cryptocurrencies. For example, the Centra Tech Website
currently advertises that Centra Tech A'offers blockchain
products such as a Wallet to store digital assets, a Prepaid
Card to spend the digital assets, and three soon to be released
products and services? which include a Marketplace to buy goods
with the digital assets, a cryptocurrency Exchange Platform to
buy, sell and trade digital assets, and a open-source hyper
speed DPOS Blockchain.''

The following individuals, among others, are or
have been employed at Centra Tech :

i.

SOHRAB SHARMA, a/k/a nSam Sharmaz'' the

defendant? was a founder of Centra Tech, its President, and its
Chief Technology Officer. On October 31, 2017, Centra Tech
announced that SHARMA was nstepping aside to support the

continued growth of the companyz' and announced a nreconstituted
executive management team'' that did not include SHARMA .

ii.

ROBERT FARKAS? a/k/a nBobr'' has held various

positions at Centra Tech, including as its chief marketing
officer and chief operating officer.

c. The Bancorp, Inc. ChBancorp'') is a Delaware-based
financial services company with offices throughout the United
States . Bancorp provides a variety of financial services to
companies and individuals, including issuing debit and prepaid
cards, and payments processing, which it does by virtue of
contractual partnerships with other financial services companies
such as Visa and Mastercard , among others .

d.

Visa Inc . (uvisa/') is a U.s.-based multinational

financial services corporation headquartered in Foster Cityr
California . Visa facilitates electronic funds transfers
throughout the world, most commonly through nVisa/'-branded
credit cards and debit cards.

e.

Mastercard Incorporated (uMastercard'') is a U.S.-

based multinational financial services corporation headquartered
in Purchase? New York. Mastercard's principal business is to
process payments between the banks of merchants and the card
issuing banks or credj.t unions of the purchasers who use the
nMastercard'' brand debit and credit cards to make purchases .

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 7 of 25

Relevant Regulatory B aekground and Definitions

1l. An ninitial coin offering'' (nICO'') is a type of
fundraising event in which an entity offers participants a
unique digital ncoin'' or utoken'' in exchange for consideration.
The consideration often comes in the form of nvirtual currency''
or ncryptocurrency,'' but can also be ufiat currencyz'' which is
currency, like the U .S . dollar and the Euro? that a government
has declared to be legal tender, but is not backed by a physical
commodity. nVirtual currency'' or ncryptocurrency'' is a digital
representation of value that can be digitally traded and
functions as (1) a medium of exchange: (2) a unit of account,

and/or (3) a store of value, but does not have legal tender
status. Unlike fiat currency, like the U .S. dollar and the

Euro, virtual currency is not issued by any jurisdiction and
functions only by agreement within the community of users of
that particular currency. Examples of virtual currency are
Bitcoin and Ether .l

12. The tokens or coins issued in an ICO are issued and
distributed on a ublockchain'' or cryptographically-secured
ledger. Tokens often are also listed and traded on online
platformsz typically called virtual currency exchanges, and they
usually trade for other djgital assets or fiat currencies.
Often, tokens are listed and tradeable immediately after they
are issued .
13. ICOs are typically announced and promoted through the
Internet and e-mail. Issuers usually release a ï'whitepaper'' or

nwhite paper'' describing the project and the terms of the TCO.

In order to participate in the ICO, investors are generally
required to transfer funds to the issuer. After the completion
of the ICO, the issuer will distribute its unique ncoin'' or
utoken'' to the participants . The tokens may entitle the holders
to certain rights related to a venture underlying the ICO, such
as rights to profits, shares of assets, rights to use certain

services provided by the issuer, and/or voting rights . These
tokens m ay also be listed on on line p latforms, often called
virtual currency exchanges, and be tradable for virtual
currencies.

1 Based on my training, experience, and participation in this
investigation, I have learned that nEther'' is a cryptocurrency
whose blockchain is generated by the Ethereum platform, and the
term nEther'' is sometimes used interchangeab ly with 'NEth ereum .''

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 8 of 25

11. Under Section 2(a)(1) of the Securities Act of 1933/ a
security includes nan investment contract.'' 15 U.S.C . 5 775 .
An ninvestment contract'' is a contract, transaction or scheme
nwhereby a person invests his money in a common enterpriae and
is 1ed to expect profits solely from the efforts of the promoter
or a third party .'' S.S.C. v . W.J. Howey Co., 328 U.S . 293, 29899 (1946). nThe test is whether the scheme involves an
investment of money in a common enterprise With profits to come
solely from the efforts of others.'' Td. at 301. Importantly,
the economic realities of the transaction or product and not its
name determine whether the instrument is a security. United
Hous. Found, Inc. v . Forman, 421 U .S. 837, 85l (1975). Pursuant

to Sections 5(a) and 5 (c) of the Securities Act, a company or
individual conducting an offer or sale of securities to the
public must file a registration statement with the SEC . 15

U .S.C. 5 77e (a) and (c).
Overview of th e Scheme to Defraud

15.

From at least July 2017 up to and including the day of

this Complaint? SOHRAB SHARMA, a/k/a nSam Sharmar'' and ROBERT
FARKAS, a/k/a nBob,'' the defendants, and others known and
unknown, participated in a scheme to defraud purchasers of
Centra Tech cryptocurrencies by making material
m isrepresentations about Centra Tech, its purported partnerships
with Bancorp, Visa, and Mastercard, its productsr its licensing
in varioua states, and its executive personnel. Through these
misrepresentations, SHARMA and FARKAS caused investors to

purchase more than $25 million worth of Centra Tech

cryptocurrencies, which function as unregistered securities,
during the time period of Centra Tech's initial coin offering.
The centra Toeh ICO

16. As set forth in greater detail below, based on my
participation in this investigation and my review of reports and
records prepared by others, from in or about July 2017 through
in or about October 2017, Centra Tech raised capital, by
offering unregistered securities via an ICO, to operate what
Centra Tech advertised would be the world's first multi-

blockchain debit card (the nCentra Tech ICO''). In sum, Centra
Tech accepted digital currency from investors in exchange for

Centra Tokens that Centra Tech stated could be nexchange gd)
.

on the Cryptocurrency exchanges for a profit'' and would

''allowl) users to join (Centra Tech's) success and misaion while
generating a profit.'' (emphasis added). In doing so, Centra
Tech made multiple false statements, including on the Centra
Tech Website and in materials posted to the Centra Tech Website,

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 9 of 25

regarding, among other things, (a) the nCentra Card'' or the

nCentra Debit Cardz'' a debit card that was falsely advertised as
one that would allow users to make purchases using any
blockchain currency of choice and would Work at any location

that accepted Visa or Mastercard, (b) Centra Tech's partnerships
with Bancorp, Visa, and Mastercard, which did not exist, (c)
individual state licenses held by Centra Tech, at least some of

which did not exist, and (d) the identity of one of Centra
Tech's executives, who does not appear to exist.

Based on my review of publicly available information
and records provided by Centra Tech to representatives of the
SEC? among other sources, I have learned the following, in
subatance and in part :
a. On or about July 23, 2017, Centra Tech issued a
press release that it paid to be published on the website

''cointelegraph .com'' (the nJuly 23 Press Release''). In the July
23 Press Release, Centra Tech described the Centra Tech ICO as
ntruly a ground floor opportunity to be part of a global
solution to the blockchain currency dilemma that offers a
comprehensive rewards program for b0th token and card holders
while giving the ability to spend your cryptocurrency in real
time with no fees.'' The July 23 Press Release also touted

Centra Teeh's products: (1) the ''Centra Debit Card'' which
purported to ''enablegl users to make purchases using their
blockchain currency of choicer'' and nwork g) anywhere that
aceepts Visa or Mastercardz'' (2) the nCentra Wallet App,'' which
nmakes it easy for people to register for the Centra Debit Card,
store their cryptocurrency assets, as well as control its

functionsz'' and (3) ncBay,'? the nhorld's first Amazon type of
marketplace created especially for cryptocurrency acceptance .''
The July 23 Press Release also advertised Centra Tech's
nCurrency Conversion Engine'' as allowing users X'the ability to
spend their assets anywhere in the world that accepts Visa

and/or Mastercard.''
b.
On or about July 25, 2017, Centra Tech issued a
press release that it paid to be published on the website

Bitcoin .com (the nluly 25 Press Release//). In the July 25 Press
Release, Centra Tech described the Centra Tech ICO as ''truly a
ground floor opportunity to be part of a global solution to the
blockchain currency dilemma that offers a comprehensive rewards
program for both token and card holders while giving the ability
to spend your cryptocurrency in real time with no fees.'' The

July 25 Press Release also touted Centra Tech's products: (1)
the nCentra Debit Card'' which purported to nenableu users to

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 10 of 25

make purchases using their blockchain currency of choicez' and
uworkll anywhere that accepts Visa or Mastercardp'' (2) the
uCentra Wallet App,'' which ''makes it easy for people to register
for the Centra Debit Card, store their cryptocurrency assets, as

well as control its functionsr'' and (3) ncBay/'' the uworld/s
first Amazon type of marketplace created especially for
cryptocurrency acceptancez' The July 25 Press Release also
advertised Centra Tech's nCurrency Conversion Engine,'' as
allowing users nthe ability to spend their assets anywhere

the world that aecepts Visa and/or Mastercard.''
c. Centra Tech also posted several different
versions of a white paper advertising the Centra Tech ICO on the
Centra Tech Website . A version of the ICO White Paper that was
downloaded from the Centra Tech Website on or about August 3,

2017 and labeled ''FINAL DRAFT/' (nWhite Paper-l'') contained

several statements describing the ICO and the Centra êard using
terminology indicative of a securities offering . For example:
i. White Paper-l described the Centra Tech ICO as a
token offering for which 1O0 Centra Tokens, or ''CTR''s, would be
sold for 1 ETH . Based on my trainingz experience, and
participation in this investigation? I have learned that 'CETH''
is the currency code for Ether, a cryptocurrency whose
blockchain is generated by the Ethereum platform .
ii. Centra Tech stated that it would be offering '168%

of a11 (Centra) Tokens to be created for purchase in our crowd
sale to the public'' and would nallocate 2O% of a11 (Central
Tokens created to distribution of bug bounty, business

development, community prolects, market expansion, and more''
while nltlhe remaining l2% w11l be distributed to Centra Techs
founders, early investors, and employees as an incentive to
create a long lasting mutual interest and dedication to the
tokens and their prolonged valuez'

iii. In providing details about the Centra Card and
the Centra Tech ICO, White Paper-l referenced different levels
of investment opportunity:
1 .The nCentra Black Card founders edition'' was
to be issued to nour first 500 ICO backers whom purchase with
100+ ETH'' and would carry with it an nenhanced rewards program .''
2 .The ''Centra Gold Card limited edition'' would
be nallocated to our first 1000 contributors whom purchase CTR

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 11 of 25

Tokens with 30+ ETHZ' and would also carry an nenhanced rewards
p rogram .'/
3. The nCentra Blue & Virtual Card'' would be
the usignature and traditional card.''
iv. White Paper-l advertised multiple nrewards''
programs for Centra Token holders. For example, White Paper-l
advertised that Centra Token holders would receive a ''.8% ETH''

reward for every transaction in the nnetwork'' (the nNetwork
Rewards Program'/). This was ïn contrast to another rewards
program advertised in White Paper-l, which offered nCard rewards
of up to 2% of your purchases made on the Centra card z' Based
on my review of White Paper-l, and representations made by

SOHRAB SHARMA, a/k/a nSam Sharmaz' the defendantr as described
in paragraph 3O.e., below, explaining that nthrough our revenue
share we actually give .8 percent of that away to token holders

as part of our program to join the Centra Tokens,'' I believe the
Network Rewards Program functions like a dividend in that it is
offering a share - .8% ETH - of Centra Tech's revenue .
v . Although it claimed that holders of the Centra
Token nby no means own any securities or interest in Centra
Techz'' and that the Centra Tokens uare not securities nor
shares/'' White Paper-l promised that Centra Token purchasers
would nbe able to place their wallet to use on Centra Debit

card? or exchange them gthe Centra Tokensj on the Cryptocurrency

exchanges for a profit.'' White Paper-l also claimed that the
Centra Card and Centra Wallet were nalready live in beta,'' and
that Centra Tech was ''offering our initial crowd sale of tokens
to appropriately fund the vision of Centra Tech's future.'' It
further claimed that Centa Tech's 'hinitial coin offering allows

users to join our success and mission while generating a
p rofit.'' (emphasis added).
vi. White Paper-l also contained several
misrepresentations, as described further in paragraphs 34
through 13, below, about Centra Tech's relationships with
financial services institutions. For example:
1. In describing the Centra Card, White Paper-l
stated : nFor our United States clients the Centra Card will be
a Visa card while for international users the Centra card issued
will be a Mastercard. . . . The Centra Card allows a11 supported
cryptocurrencies to become spendable in real time based on the
governm ent fiat being used at the time the card is used at a
participating location that accepts Visa or Mastercardz'

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2. White Paper-l contained multiple images of
Centra Cards with the nvisa'' logo .
3. White Paper-l also stated that one benefit
and advantage of the Centra Card was ''Access to 36+ Million

Points of Sale where Visa and/or Master-card is accepted in 200+
countries.''

4. A product comparison table in White Paper-l
reported that the issuers of the Centra Card were PMastercard
and Visa .''
5. White Paper-l contained a timeline of Centra

Tech's ''milestone itemsr'' including a nMajor Banking Partnership
signed and license agreement with VISA USA Inc formulated'' in
January 2017, and a nBeta Launch of Centra Black Card and Centra
Wallet App Live'' in March 2017.

6. White Paper-l also used the logos of
Bancorp , Visa and Mastercard when describing Centra Techfs
p artners .
vii. White Paper-l stated that nCentra Tech holds
individual licenses in 38 states namely Alabama? Arizona,
Alaska, Arkansas, Connecticut, Delaware, District of Columbia,
Florida? Georgia, Idaho, Iowa, Kansas, Kentucky, Louisiana,
Maine, Maryland, Mississippi, Nevada, Nebraska, New Hampshire?
New Jersey, New York, North Carolina, North Dakota, Ohio,
Oklahoma, Pennsylvania, Oregon, Rhode Island, South Dakota,
Tennessee, Texas, Vermont? Virginiaz Washington, and West
Virginia.'' It further stated that the licenses nare held under
categories of Money Transmitter, Sales of Checks, Electronic
Money Transfers, and Seller of Paym ent Instruments .//
v iii. White Paper-l advertised the ncentra Tech Team ''
as comprising, among other individuals, SHARMA as the ''CTO & CoFounder/'; FARKAS as the ''CMO''; and nMichael Edwards'/ as the ''CEO
& Co-Founder .''

SHAKMA'S Representations in Connection with the
Con tra Tech ICO

18. On or about August 14, 2017, SOHRAB SHARMA, a/k/a nSam
Sharm ar'' the defendant, was interviewed by Neocash Radio , a
cryptocurrency podcast, abou t the Centra Tech ICO . Based on m y

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 13 of 25

review of a recording of the interviewz I have learned that
SHARMA stated, among other things, the following:z

a.

n Elqnternationally, we currently have our license

with Mastercard, to service international clients.
Domestically, we do have the Visa partnership, so we are able to
issue Visa cards domestically and Mastercards internationally .''

b.
nRight now we are currently in our live Beta
stage, which we have members of our internal organization as
well as some external that have gotten our Centra Black Founder
cards recently. Werre going through . . . pretty much a phase

two of testing rlght now where we are just going through daily
transactionsz testing volume,
results so far on it.''

and werve gotten really good

SHARMA also stated that Centra Tech had npretty
much a successful test rate in terms of errors, in terms of
proof processes and the whole flow of the card attaching to the
app,'' when discussing the Centra Wallet.

d . SHARMA identified ''Mike Edwards'' as a ''VP and cofounder'' who was an early investor in Centra Tech .
e.
In describing the rewards system for purchasers
in the ICO, SHARMA stated: ''The rewards percentage that we get
from Visa and Mastercard through our revenue share we actually

give .8 percent of that away to token holders as part of our

program to loin the Centra tokensz'
f.

nERlight now is a great time to join our system,

we have a token sale that is going on, it finishes on October

5th . . . we're currently a little bit north of $1O million
raised in our first eight days of our crowd sale so I definitely
want to thank a11 of my contributors and anyone who is listening

for joining that as well.''
g . SHARMA stated that there was currently a 20%
token bonus on top of the current token sale that ''can be
redeemed via email.''

2 The summaries and transcript of the recorded interview set
forth herein is based on a preliminary draft transcription and

remains sublect to revjsion.

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 14 of 25

h.
nWe have a coup le of large deals we're wo rking on
right now with a few companies so we should be over by I would
say early September .''

i.
SHARMA directed listeners to the Centra Tech
website, www .centra .tech , to find out more about the Centra Tech
IC0 : nYou can go to our website, www .centra .tech ? and you can
click the token sale page as well as our white paper is on there

and you can lust get an insight of everything from A to Z.''
j.

SHARMA stated that while Centra Tech was licensed

in 38 states, nthe states that we are operating in currently for

licensing purposes is just so the ability to withdraw and
transmit your Bitcoins. As far as actually utilizing the card
itself to the wallet and spending the cryptocurrencies, that's
available in a).l states .''
k. SHARMA also stated that he was able to work
through the U.S . licensing issues with a contact he knew at
Metropolitan Commercial Bank. SHARMA stated that nour system is
connected to the bank and we're connected to the clientsz'
Additional R epresentations by FARRAS

19. Based on my review of records provided by Centra Tech
to the SEC, and which were provided to me in connection with
this investigation, I have learned, in substance and in part,
the following:

a.

On or about August 30, 2017, SOHRAB SHARMA, a/k/a

nSam Sharmaz'' the defendant, sent an email to an individual not

at Centra Tech, and copied ROBERT FARKAS, a/k/a ''Bobr'' the
defendant, to the email. In that email, SHARMA conveyed a
message that SHARMA had received from Bancorp stating the
following :
Mr. Sharma : I left a voicemail on your phone,
but I am following up here as well . CENTRA
TECH IS HEREBY DIRECTED TO CEASE AND DESIST
FROM REPRESENTING THAT THE BANCORP BANK HAS
ANY CONNECTION W ITH, OR IS THE ISSUER OF ANY
CARD PRODUCTS RELATED TO CENTRA TECH . YOU ARE
ALSO DIRECTED TO CEASE AN D DESIST USING OUR
LOGO OR OTHER IMAGES IN CONNECTION WITH THE
MARKETING OF ANY CARD PRODUCTS OR WALLETS YOU
OFFER . Please REMOVE any and all references
to The Bancorp Bank or The Bancorp Inc . from
14

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 15 of 25

any and a11 websitesz marketing materials or
other communications, including blogs as this
has not been authorized by The Bancorp. I
expect you will be hearing from federal
banking regulators as well.
b. On or about September 6, 2017, FARKAS exchanged
emails with an individual at a company that provides a search
engine allowing users to look up# confirm, and validate
transactions that have taken place on the Ethereum blockchain

(''company-l''l. In the emails, FARKAS inquired about how to
obtain advertising space on Company-l's website, and stated,
substance and in part, the following:
1 know there are some past issues but we are now
complete on our Pre-ICO raised over 1OM in ETH and
have been verified by a11 of our staff on Token Market
We have ad space everywhere else except here . Please
1et me know if you need any identifying documents or
anything to proceed with our ad space.

FARKAS also provided the adveruising text that he wanted
Company-l to post'' nCentra Card @ & Centra Wallet @ Now
available Worldwide l'' FARKAS signed the email ''Robert Farkas
CMO.'' After receiving a response from Company-l that it was

nnot able to cater to (Centra Techfs) advertising needs at this
point Ein) time,'' FARKAS forwarded the emails to
l'ssharma4gl@gmail.comz'' an email address used by SHARMA .?
c.

In or ab out early September 2017, FARKAS, using

the email address nsupportecentra.techr'' and at times signing
his name %'Bobz'' or nRob ert Farkas CMO Centra p'' exchanged a
series of emails with an individual at a marketing company

seeking to write promotional materials and/or articles about
centra Tech (ulndividual-l/'). On or about September 6, 2017,
FARKAS described Centra Tech as follows:
The biggest problem in the crypto world is
being able to sp end your cryptocurrency
3 Based on records provided to the FBI by Google , I have learned
that SHARMA is listed as the subscriber for the email address
nssharma4gl@gmail.com z' In additionr based on my review of
records produced by Centra Tech to the SEC, I have learned that
SHARMA uses the email address h'ssharma4glegmail.com .''

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 16 of 25

effortlessly .
The Centra Card and Centra
Wallet app are the solution. Our Currency

Conversion Engine Module (CCE Module) allows
real time conversion of a11 supported
cyrptocurrencies to give the user the ability
to spend their assets in real time anywhere in
the world that accepts Visa or Mastercard .

Thanks:
Bob
On or about September 13# 2017, Individual-l appears to have
provided FARKAS with a draft of written materials related to
Centra Tech and, later that same day, FARKAS responded with
edits, including the following:
Title : Can we change it too : This company
has brought cryptocurrency into the real
world
reason being is that our card is live and
working and has been shipped to clients

already ()
''
Thanks,
Bob
20. From approximately in or about September 2017 through
in or about December 2017, FARKAS received and responded
multiple emails either directly or through the
''support@centra.tech'' email account from individuals interested
in participating in the Centra Tech ICO, interested in
purchasing Centra Tokens, or otherwise seeking information about
Centra Tech .
21. Based on my review of records provided by Centra Tech
to the SEC, I have learned, in substance and in part, that, in
or about October 2017, FARKAS registered Centra Tech as a
sponsor of nConsensus: Invest 2017,'/ a blockchain technology
summit or conference that took p lace on or about Novemb er 28,
2017 in New York C ity , New York . I have reviewed a video posted
to Centra Tech's YouTube channel on or about January 5, 2018
entitled uCentra Consensus NYC Cryptocurrency Blockckain Expo
Invest.'' The video depicts what appears to be people and
activities at the nConsensus'' Invest 2017,'' including a Centra

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 17 of 25

Tech b00th or table at the conference, and shows F'
ARKAS engaging
in conversations with various people during the conference.
Based on the foregoing, I believe that FARKAS was in New York
City? New York, on or about November 28, 2017, and engaged in
promotional and marketing activities for Centra Tech at the
%'Consensus : Invest 2017'/ conference .
The Frauduient Partnexships wiEh Bancorp , Visa, and Mastereard
22. Based on my conversations with a representative of

Bancorp (uWitness-l'') and my review of documents provided by
Bancorp, I have learned, in substance and in partz the
following:

a. In approximately August 2017, Witness-l learned
from Bancorp's marketing group that a potential investor or
purchaser of Centra Tech tokens had inquired as to whether
Bancorp had a business relationship with Centra Tech, as was
represented by Centra Tech in its marketing materials at the
time.
b.
In investigating the inquiry in approximately
August 2017, Witness-l reviewed the Centra Tech Website and a
white paper posted on the Centra Tech Website. Witness-l
discovered that Bancorp/s issuer statement, a statement
regarding who the card issuer is any time a Visa or Mastercard
image is displayed, was being used on the Centra Tech Website.
Witness-l knew by looking at the Centra Tech Website and white
paper that Bancorp would not ever work with a company such as
Centra Tech by virtue of the risk level of the product Centra
Tech was offering .
c. Witness-l reviewed Bancorp internal databases,
include Bancorp 's list of entities with which it had card
issuance relationships and entities involved in Bancorp's cobranded incentive card program, to see whether Bancorp had any
sort of relationship with Centra Tech . Through this process,
Witness-l confirmed that Bancorp did not have any relationships
with Centra Tech.
d. Witness-l took screenshots of the Centra Tech
Website, including a page that misrepresented Bancorp 's issuer
statement .
e.
One screenshot that Witness-l retained stated ,
among other things:

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 18 of 25

The Centra Card Visa Debit Card is issued by
The Bancorp Bank: member FDIC, pursuant to a
license from Visa U.S.A . Inc . ''The
Bankcorp''4 and nThe Bancorp Bank'' are
registered trademarks of The Bankcorp Bank @

2014. Use of the Card is subject to the
terms and conditions of the applicable
Cardholder Agreement and fee schedule,
any .
The Centra Card Mastercard@ Debit Card is
issued by The Bancorp Bank, member FDIC,
pursuant to a license from Mastercard
International Incorporated. uThe Bankcorp''
and nThe Bancorp Bank'' are registered
trademarks of The Bankcorp Bank @ 2014 . Use

of the Card is subject to the terms and

conditions of the applicable Cardholder
Agreement and fee schedule, j.f any.

f, As described above, Witness-l reviewed a white
paper that was posted to the Centra Tech Website in August 2017.
Witness-l recalled that the white paper contained multiple
misrepresentations, including about Centra Tech's purported
relationship with Bancorp .
g . In approximately August 2017, Witness-l attempted
to reach individuals at Centra Tech through, among other
methods, the nContact Us'' portion of the Centra Tech Website to
request that Centra Tech remove the Bancorp logo and the false
statements regarding Centra Tech's purported relationship with
Bancorp . Witness-l did not receive a response from Centra Tech.
h.

Based on my conversations with another

representative of Bancorp (n%itness-z'') and my review of
documents provided by Bancorp, I have learned, in substance and
in part, that, on or about August 3O, 2017, Bancorp sent a cease
and desist notice to Centra Tech to which Centra Tech did not
respond .
23. Based on my conversations with a representative of

Visa tnWitness-3''l and my review of documents provided by Visa,
I have learned? in substance and in part, the following:
4 This excerpt from the Centra Tech Website has not been altered
to correct spelling or other errors. In this excerpt, nBancorp''
is also spelled nBankcorp .''

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 19 of 25

a. On or about October 1O, 2017, Visa became aware
that Centra Tech was uaing the Visa name and logo on marketing
materials in connection with the Centra Card and the Centra Tech
ICO .

b . Visa employees researched whether Visa had any
relationship, direct or indirect, with Centra Tech . Visa
determined that it had no relationship with Centra Tech.
c. Visa employees took screenshots of portions of
the Centra Tech Website using and showing the Visa name and
trademark, including of purported Centra Cards with the Visa
logo .
d. On or about October 1O, 2017, Visa's Legal
Department sent an email to Centra Tech, at support@centra.tech,
attaching a cease and desist letter (the nOctober 10 Letter'/).
In the October 10 Letterr Visa stated, in part:
It has come to our attention that Centra

Tech ('Acentra'') is using the Visa-owned
Marks on its site https://www.centra.tech as
well as on its various social media sites

(e.g ., Facebook, Twitter, Instagram ,
YouTube) and other mediums. It appears
Centra is purporting to be an authorized
distributor of VISA payment cards utilizing
cryptocurrency technology . . . . However, to
the best of our knowledge and good faith
belief, Centra is not authorized to use the
Visa-owned Marks in this manner, nor is it
authorized to issue, sell, or otherw ise
distribute VISA payment cards. If this is
not the case, please advise and exp lain
immediately, i.e., if Centra is working with
an authorized Visa Issuing bank.

Visa attached to the October 10 Letter multiple screenshots from
the Centra Tech Website in which Centra Tech had misappropriated
the Visa trademark.
e.
In the Octob er 10 Letter, Visa requested that
Centra Tech cease and desist from using Visa's trademarks and
npromoting that it is an authorized distributor of VISA payment
cards,'' and for Centra Tech to remove a11 references to Visa
from the Centra Tech Website and any promotional materials.

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 20 of 25

Visa also requested that Centra Tech uidentify the bank or

financial institution it is working with (if any) to issue a
purported VISA payment card product.''
f.

In response to the October 10 Letter, SOHRAB

SHARMA, a/k/a nSam Sharmar'' the defendant, provided Visa with an
acknowledgment that he had received the October 10 Letter, but
did not identify any financial institutions with which Centra
Tech was working to issue a Visa payment card product .
24. Based on my Peview of records provided by Centra Tech
to the SEC? and which were provided to me in connection with
this investigation, I have learned, in substance and in part,
the following :
a.

On or about October 10, 2017, SOHRAB SHARMA ,

a/k/a uSam Sharmaz'' the defendant? using the email address
''sam@centra.tech,'' emailed a response to Visa's October 10
Letter, stating:
This matter has been brought to my
attention. I will have this matter rectified
in 48 hours. We are currently in the process
of finalizing our Co-branded Prepaid Card
Program? but might not meet the Nov lst lock
out deadlines for submission from our
issuing bank whom is an authorized visa
issuer for card design approval, So can see
where this issue might of came from .
However, I have immediately contacted my web
developers to remove a11 issues and I will

have this document (a cease and desist
acknowledgment) signed and returned within
48 hours .
Thank you ,
Sam Sharma
b . On or about Octob er 1l, 2017, Visa responded to
SHARMA'S email, and requested that he ''advise of the Visa
issuing bank you are working with . ''

c .On or about October 12, 2017, SHARMA responded again
via email using the nsam@centra .tech'' email account and stated:
nAs far as the issuing bank we have an MNDA in place currently .
VISA will soon get our information for Card Design approval and
20

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 21 of 25

program specs from our future issu ing bank in the US .'' SHARMA
signed the email, uThank you? Sam.'' Based on my training and
experience, I believe SHARMA was claiming that he had a Mutual
Non-Disclosure Agreement with the purported issuing bank in this
email and that he therefore could not disclose its identity .

d.On or about October 14, 2017, Visa responded to
SHARMA'S email, noting that Centra Tech Was still using the Visa
trademark and Visa name in its promotional materialsz including
in videos in which SHARMA appeared, and reiterated its demand
that Centra Tech stop using the Visa name. Visa also repeated
its request that SHARMA identify the b ank that Centra Tech was
nallegedly working with.''
e. Based on my conversations with Witness-3, I have
learned that, in response to Visa's multiple requests for Centra
Tech to identify the Visa card issuing bank with which it
purported to have a relationship, neither SHARMA nor anyone at
Centra Tech identified such an issuing bank.
25. Based on my conversations with a representative of

Mastercard (nWitness-4'')l I have learned, in substance and in
part, that Mastercard's internal records of licensing agreements
and relationships with card-issuing banks and other third

parties contains no record of any retationship, either direct or
indirect , with Centra Tech .

26. Based on my review of the current version of the
Centra Tech Website and a white paper published via the Centra
Tech Website, as of March 26, 2018, I have learned that Centra
Tech is not currently using the Bancorp, Visa or Mastercard
names or logos.
27. As described in paragraph 17.c.viiw above, White
Paper-l represented that Centra Tech held licenses nunder
categories of Money Transmitter? Sales of Checks, Electronic
Money Transfers, and Seller of Payment Instrum ents ,'' in 38

listed states (the nState Licensing List''). Based on my review,
on or about March 12, 2018, of a database maintained by the
Nationwide Multistate Licensing System, a financial services
industry online registration and licensing database, and my
review of certain state licensing databases, I have learned,
substance and in part, that th e following states on the State
Licensing List have no current record for Centra Tech based on
available public searches: Arizona, Connecticut, Delaware,
Florida, New Jersey , New York or South Dakota .

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 22 of 25

nM ich ael Edwards''

28. As described in paragraph 17.c.viii, above, White
Paper-l listed nMichael Edwards'' as Centra Tech's ''CEO & CoFounder.'' White Paper-l also included a picture of MMichael
Edwards.'' Based on open source searches of this image, I have
learned that the picture of nMichael Edwards'' in White Paper-l
is actually a picture associated with an individual by a
different name who is a Canadian physiology professor.
29. Based on my review of records provided by the SEC,
have learned, in substance and in part, that, on or about August
3, 2017, a user profile page appeared on Linkedln, a businessand employment-oriented social networking service that operates
via websites and mobile apps, for nMichael Edwards.'' The
Linkedln page stated that ''Michael Edwards'' had 'llaunched Centra
Tech with the mission to design the world's first multiblockchain asset debit card'' and had managed various aspects of
Centra Tech's Centra Card and Centra Wallet programs, including

n gelstablished licensing and partnership terms with Visa &
Mastercard.'' The Linkedln page also stated that ''Michael
Edwards'' was affiliated with Harvard University.

3O. Based on my review of currently-available content on
the Linkedln website? I have learned that the ''Michael Edwards''
Linkedln page no longer exists.
31. Based on Internet searches for a nMichael Edwards'' who
is or was a co-founder or CEO of Centra Tech, I have learned
that there is limited information about such an individual. For
example, I have found no interviews of uMichael Edwards'' in
connection w ith Centra Tech or the Centra Tech ICO , and the name
nMichael Edwards'' no longer appears on the Centra Tech Website
or Centra Tech online promotional materials. Based on the
information described above, and based on my training,
experience, and participation in this investigation, I believe
that a nMichael Edwards'' who was at some point ''CEO & CoFounder'' of Centra Tech may not exist.
The Centra Toch ICO Investors

32. Based on my training, experience, and participation in
this investigation, I have learned that compan ies like Centra
Tech that offer cryptocurrency are required to keep a record of
identification information-including names and addresses-of
individuals purchasing their cryptocurrency. Based on my review

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 23 of 25

of records provided by Centra Tech to the SEC, 1 have learned,
in substance and in part, the following:
a . Centra Tech provided a spreadsheet labeled
nCentra Token Sale Details'' to the SEC , The spreadsheet
contains several tabs, including tabs labeled MCentraToken,''
ncentrasale,'' and nCentra Token Owner z '

b . The CentraToken tab contains information
regarding more than 1800 purchases of Centra Tokens from b etween
on or about July 30 to August 26, 2017. TWo of the listed
investors reside in New York City, New York, within the Southern
District of New York.
c.
The Centrasale tab contains information regarding
more than 1700 purchases of Centra Tokens from between on or
about September 19 to September 26? 2017. Three of the listed
investors reside in New York City, New York, within the Southern
District of New York.
Extradition Research , Document Destruction ,
and International Travel
-

33. Based on my discussions with representatives of the
SEC, I have learned, in substance and in part, that in or about
the fourth quarter of 2017 the SEC issued an initial subpoena to
Centra Tech for documents and other inform ation, and that SOHRAB

SHARMA, a/k/a ''Sam Sharmat'' and ROBERT FARKAS, a/k/a ''Bob,'' the
defendants, are thus aware of the SEC'S investigation .
34. Based on my conversations with an attorney who is

employed by a financial regulatory authority (''Witness-s/'), I
have learned, in substance and in part, the following :
a.

Witness-s knows an attorney who was until

recently employed by Centra Tech (''Employee-l'').
b . Witness-s had several telephone conversations and
electronic communications with Employee-l on or about March 29
and 30, 2018.
c . During these communications, Employee-l told
Witness-s the following, in substance and in part:
i.
Employee-l learned earlier this week that
the SEC has been investigating whether Centra Tech has engaged
in fraudulent activity .
23

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 24 of 25

ii.

ROBERT FARKAS, a/k/a nBobp'' the defendant,

recently asked Employee-l via email to conduct research
regarding foreign extradition laws .

iii.
After Employee-l performed this extradition
research and reported the results to FARKAS, FARKAS approached
Employee-l in person and stated, in substance and in part, that
he had deleted his email asking Employee-l to perform this
extradition research. Based on FARKAS' demeanor during this
interaction and the way in which he made that statement about
deleting his email, Employee-l understood FARKAS to be
suggesting that Employee-l should also delete the copy of that
email that Employee-l had received from FARKAS regarding the
extradition research.
d.
Employee-l has not seen an individual Employee-l
described to Witness-s as the nowner'' of Centra Tech in over a
week -- which I believe, based on my training and experience and
participation in the investigation of this case, to be a

reference to SOHRAB SHARMA, a/k/a %'sam Sharma,'' the defendant.
e.
Employee-l also learned this week that Centra
Tech 's bank account has been depleted .

f.
Employee-l conveyed that Centra Tech has
terminated virtually a11 of its employees except certain top
executives such as SHARMA and FARMAS.

26. Based on my review of records provided by Delta
Airlines? I have learned that on or about Mardh 27, 2018, ROBERT

FARKAS, a/k/a %'Boby'' the defendant, booked Delta Airlines
flights for himself and a co-traveler whose name I recognize to

be the name of an employee at Centra Tech (nEmplbyee-z'') to f1y
from Fort Lauderdale, Florida to Incheon, South Korea via a
Delta Airlines flight leaving Fort Lauderdale-Hollywood
International Airport in Florida on or about April 1, 2018
approximately 8:O0PM, with a stopover at Hartfield-lackson
Atlanta International Airport in Georgia to catch a connecting
Delta Airlines flight that will arrive at Incheon International
Airport in South Korea on or about April 2, 2018 . According to
these records , FARKAS and Employee-z have also booked return
flights that would have them leave from Incheon International
Airport in South Korea on or about April 5, 2018 and arrive at
Fort Lauderdale-Hoilywood International Airport in Florida
about April 5, 2018.

 Case 0:18-mj-06165-PMH Document 1 Entered on FLSD Docket 04/02/2018 Page 25 of 25

WHEREFORE, I respectfully request that arrest warrants be

issued for SOHRAB SHARMA, a/k/a nsam Sharma,'' and ROBERT FARKAS,
a/k/a nBobz'' the defendants? and that they be arrested and
imprisoned or bailed, as the case may be,

BRANDON RACZ

Special Agent
Federal Bureau of Investigation
Sworn to before me this
31st day of March 2018

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HON Rq LE JAMES L. COTY
UN TEj STATES MAGISTRATE JUDGE
SOUTéERN DISTRICT OF NEW YORK

25