Case Document 13 Filed 02/12/18 Page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA Criminal F6 QR "24.11 

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

RICHARD PINEDO,
I 
Defendant. FEB 1 2 2013

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 bets 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 su?cient facts exist that the defendant committed the
olfense to which he is pleading guilty.

1. From approximately 2014 through December 2017, the defendant, RICHARD
PINEDO, operated an online service called ?Auction Essistance.? Through 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 1.

2. PINEDO sold bank account numbers through interstate and foreign commerce,
speci?cally over the intemet. 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
intemet. 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 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 numbers as ameans of verifying
a user?s identity. To circumvent this requirement, certain users (hereinafter ??Users?) registered
for Company 1?s online services with bank account numbers in the names of other people.
PINEDO sold Users bank account numbers over the intemet to aid and abet, and in connection
with, this scheme to defraud Company 1 by means of internet in interstate and
foreign commerce.

4. After acquiring bank account numbers ?om 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 I 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 amomts of those trial deposits, thereby further aiding the Users in their scheme to
circumvent veri?cation processes by Company 1.

5. PINEDO ?equently purchased bank account numbers ?om 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 sold bank account numbers were outside the United

States.

6. In total, PINEDO knowingly transferred, possessed, and used, without lawful
authority, hundreds of bank account numbers to aid and abet, and in connection with, the use of
the wires in interstate and foreign commerce to defeat security measures employed by Company
1. PINEDO personally collected tens of thousands of dollars, and more than $1,000 during a one?

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

Case Document 13 Filed 02/12/18 Page 3 of 4



ACCEPTANCE

Theprecedjng statement theCounwith
a?ctual basis pleato?ae charge against me. Itdoesnotinludc allofthe facts
known tome regarding this o??nse. Innkemis statement hnwingly amlvoluntarily and
becauselam, m?acggn?tyofthecrhm charged. No?neatshavebeenmdemnemraml
underthe in?uence ofanything that could impede myabilily tounderstam this Statement ofthe
O?'eme ?JIly.

Ilnve readevely word ofthis Statement ofthe O?ieme, orlnve haditreadtome.
Pmsuant toFederaIRule ofCriminal Pmcedme 11,a?er consulting with my attormys, Iagree
andstipulate tothis Slatemem ofthe O?ense, mldechremderpemlty ofpetjury Ihatit'smn
andconect.

 

Date: 3211321 I 

Defendant

AC OWLEDGMENT

Ihave readthis Statement ofthe Offense, andhave reviewed itwithmy client I
concur desire toadOptands?pulate tothis Statement ofthe 0m: astme and

mm.

Date: L3, I 
Ian sem
Attorney ibr Defendant

Case Document 13 Filed 02/12/18 Page 4 of 4

ROBERT S. MUELLER, 111
Special Counsel



 

J'ezjinie S. Rhee
Se ior Assistant Special Counsel

L. Rush Atkinson
Ryan K. Dickey

Assistant Special Counsels
The Special Counsel?s Of?ce