as a, . 0 mews fogf?i) . . . ,9 i $00 S55 SCANLON51/0 4 UNITED STATES DISTRICT COURT 1 49? EASTERN DISTRICT OF NEW YORK .. .. .. .. UNITED STATES OF ANIERICA 4 against - r. NO. (T. 18, U.S.C., ANTON BOGDANOV, 982(a)(2), 982(b)(1), also known as ?Kusok,? 1028A(b), 1028A(c)(5), 1030(a)(2)(C), - 1030(c)(2)(B), Defendant. 1349, 2 and 3551 21, U.S.C., . 853(p); T. 28, U.S.C., 2461(0)) THE GRAND JURY CHARGES: INTRODUCTION At all times relevant to this Indictment, unless otherwise indicated: 1. The defendant ANTON BOGDANOV, also known as ?Kusok,? was a citizen Of Russia. 2. In or about and between June 2014 and November 2016, the defendant I ANTON BOGDANOV, together with others, fraudulently Obtained tax ?lings belonging to I Other individuals (the ?Identity Theft Victims?) via an Internal Revenue Service website. To obtain these ?lings, BOGDANOV and his co?conspirators input misappropriated personally identi?able information such as Social Security numbers and dates Of birth of the Identity Theft Victims, into the IRS website and created online profiles on behalf Of the Identity Theft Victims. By fraudulently creating these pro?les, BOGDANOV and his cO?conspirators were able to gain access to the Identity Theft Victims? prior tax ?lings, which contained, among other things, banking and earnings information, along with other PII. I . 3. The defendant ANTON BOGDANOV and others then used the Identity Theft Victims?i?ll to complete and submit new tax returns purportedly on behalf of the Identity Theft Victims. BOGDANOV and his co?conspirators completed the fraudulent tax returns in a manner aimed at inducing theIRS to issue refunds to the Identity Theft Victims. However, BOGDANOV and his co?conspirators also provided the IRS with prepaid debit . card information for cards under their control so that the refunds went to BOGDANOV and his co-conspiratcrs, and not the Identity Theft Victims. 4; Another way in which the defendant ANTON noonANov and others obtained Identity Theft Victims? PII for use in this scheme was by gaining unauthorized access to the computer systems of private tax preparation ?rms in the United States, including at least one firm located in the Eastern District of New York.- BOGDANOV and his co-conspirators gained unauthorized access to these systems by exploiting a vulnerability in a remote access program used by the tax preparation firms" employees to log in from home and while traveling. 5. - The defendant ANTON BOGDANOV and others then electronically altered the tax filings of the firms? clients so that the account and routing numbers listed in the ?lings, to which refunds were to be paid, were those of prepaid debit cards controlled by BOGDANOV and his-co?conspirators. Once BOGDANOV and his coaconspirators received fraudulently obtained refunds from the United States Department of the Treasury, the prepaid debit cards were cashed out in the United States, and a percentage of the proceeds were wired to BQGDANOV in Russia. BOGDANOV and his co?conspirators received more than $1.5 million in fraudulently obtained refunds. COUNT ONE (Conspiracy to Commit Wire Fraud) 6. The allegations contained in paragraphs one through ?ve are realleged and incorporated as if fully set forth in this paragraph. 7. In or about and between June :014 and November 2016, both dates being approximate and inclusive within the Eastern District of New York and elsewhere, the defendant ANTON BOGDANOV, also known as ?Kusok, together with others, did knowingly and intentionally conspire to devise a scheme and arti?ce to defraud the United States Department of the Treasury, and to obtain money and property from the United States Department of the Treasury. by means Of one or more materially false and fraudulent pretenses, representations and promises, and for the purpose Of executing such scheme and artifice, to transmit and cause to be transmitted by means of wire communication in interstate and foreign commerce, writings, signs, signals, pictures and sounds, to wit: electronic .communications to computers and servers in the United States and elsewhere, emails and other online communications, and monetary transfers, IOOntrary-to Title 18, United States Code, Section 1343. . (Title 18, United States Code, Sections 1349 and 3551 e_t COUNT TWO (Aggravated Identity Theft) 8. The allegations contained in paragraphs one through five are realleged and incorporated as if fully set forth in this paragraph. 9. In or about and between June .2014 and November 2016, both dates being approximate and inclusive, within the Eastern Districtof New York and elsewhere, the defendant ANTON BOGDANOV, also known as ?Kusok,? together with others, during and in relation to the crime charged in Count One, did knowingly and intentionally transfer, possess and use, without lawful authority, one or more means of identification of other persons, to wit: social security numbers and other personally identi?able information, knowing that these means of identi?cation belonged to said persons. (Title 18, United States Code, Sections 1028A(a)(l), 1028A(b), 1028A(c)(5), . COUNT THREE (Computer Intrusion and Obtaining Information) 10. The allegations contained in paragraphs one through five are realleged I and incorporated as if fully set forth in this paragraph. ll. In or about and between June 2014 and November 2016, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant ANTON BOGDANOV, also known as ?Kusok,? together 'with others, did knowingly and intentionally access one or more computers without authorization and exceed authorized access, and thereby obtain information from one or more protected computers, to, - Wit: tax filings from ?taX preparation firm computer systems, for the purpose of commercial advantage and private financial gain, and in ?irtherance' of criminal and tortious acts in violation of the laws of the United States and any State, and the value of the information obtained exceeded $5,000. (Title 18, United States Code, Sections 1030(a)(2)(C), 103 2 and 3551 gseg.) CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE 12,; The United States hereby gives notice to the defendant that, upon his conviction of the offense charged in Count One, the government will seek forfeiture in accordance with Title 18, United States Code, Section 981(a)(l)(C) and Title 28, United States Code, Section 2461(c), which require any person convicted of such offense to forfeit any property, real or personal, conStituting, or derived from, proceeds obtained directly or indirectly as a result of such offense. 13. If any of the above-described forfeitable property, as a result of any act or omission of the defendant: (0) (6) divided Without dif?culty; cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the court; has been substantially diminished in value; or has been, commingled with other property Which cannot be it is theintent of the United States, pursuant to Title 21, United States Code, Section 85 to seek forfeiture of any other property of the defendant up to the value of the forfeitable property described in this forfeiture allegation. . (Title 18, United States Code, Section Title 21, United States Code, Section 853(p); Title 28, United States Code, Section 246l(c))' . CRIMINAL FORFEITURE ALLEGATION AS TO COUNT THREE l4. The United States hereby gives notice to the defendantthat, upon his conviction of the offense charged in Count Three, the government will seek forfeiture in accordance with Title 18, United States Code, Sections 982(a)(2) and 1030(i)(l), which require any person convicted of such offense to forfeit any property constituting, or derived from, proceeds obtained directly or indirectly as a result of such offense, and such person?s interest in any personal property that was used or intended to be used to commit or to facilitate such offense. 15. ,If any of theabove?described forfeitable property, as a result of any act or omission of the defendant: . i cannot'be located upon the exercise. of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the court; has been substantially diminished in value; or 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, Sections 982(b)(l) and 1030(i)(2), to seek forfeiture of any other property 'of the defendant up to the value of the forfeitable property described in this forfeiture allegation. (Title 18, United States Code, Sections 982(a)(2), 1030(i)(l) and and Title 21, United States Code, Section 85 - A TRUE BILL OREPERS ON RICHARD P. DONOGHUE UNITED STATES ATTORNEY - EASTERN DISTRICT OF NEW YORK 2019R00637 FORM DBD-34 N0. JUN. 85 UNITED STATES DISTRICT COURT EASTERN District of NEW YORK CRIMINAL DIVISION THE UNITED STATES OF AMERICA VS. ANTON BOGDANOV, Defendant. INDICTMENT (T. 982(a)(2), 982(b)(1), 1028A(a)(1), 1030(i)(2), 1349, Zand3551 et_q.; T. 21, U..S C., ?853(p)- 28, A true bill: Forepers on