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UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA
October 2018 Grand Jury

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UNITED STATES OF AMERICA,

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Plaintiff,

I N D I C T M E N T

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v.

[1 8 U.S.C. § 1956(h): Consp ir acy
to Engage in Money Laundering; 18
U.S.C. § 1 349 : Conspiracy to
Commit Wire Fraud, Mail Fra u d , and
Bank Fraud ; 18 U.S.C. § 1343: Wire
Fraud; 18 U.S.C. § 1344(2) : Bank
Fraud ; 18 U.S.C.
§ 1956(a) (1) (B) (i) : Money
Laundering; 18 U.S . C . § 1957:
En gaging in Monetary Transactions
in Property Derived from Specified
Unlawful Activity ; 18 U.S.C.
§§ 1960(a), (b) (1) (A), (b) (1) (B),
(b) (1) (C): Operating an Unlicensed
Money Transmitting Business; 1 8
U.S.C. § 2232(a) : Destruction of
Property to Prevent Seizure; 18
U. S.C . § lOOl(a) (2): False
Statements ; 18 U.S.C.
§ 1028A(a) (1): Aggravated Identity
Theft; 1 8 U. S . C. § 2(a): Aiding
and Abetting; 1 8 U.S.C. §§ 981 an d
982 a nd 28 U. S . C . § 246 1(c):
Crimi nal Fo rf eiture]

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VALENT INE IRO,
aka "I ro Enterprises,"
aka "Valentine Obinna I ro ,"
aka " Obinna Iro ,"
aka " Obinna Nassa,"
CHUKWUDI CHR I STOGUNUS IGBOKWE,
aka " Christogunus C .
Igbokwe,"
aka " Chris Kudon ,"
aka "At ete ,"
aka "Still Kudon ,"
JERRY ELO IKOGHO ,
aka "J Man,"
IZU CHUKWU KINGSLEY UMEJESI,
aka " Kingsley Umejesi, "
aka "Armen i an Man,"
aka "Kingsley LA,"
aka "I zukin g Aka Aku ,"
ADEGOKE MOSES OGUNGBE ,
aka "P & P Motors,"
aka "Pp, "
ALBERT LEWIS CATHEY,
aka "Alb, "
aka "Abert Jag,"
aka "Al,"
TIT YAYE MARINA MANSBANGURA,
aka "Tityaye Igb okwe ,"
aka "Marina Mansour ,"
aka "Marina Mansaray,"

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aka “Marina Tityaye Mans
Bangura,”
CHUKWUDI COLLINS AJAEZE,
aka “Thank You Jesus”
EKENE AUGUSTINE EKECHUKWU,
aka “Ogedi Power,”
aka “Power,”
CHUKS EROHA,
aka “Chuks Nassa Iro,”
aka “Nassa,”
aka “Prince Chuddy,”
aka “Nurse Chuddy,”
COLLINS NNAEMEKA OJIMBA,
aka “Collins Emeka Ojimba,”
aka “Ojimba Collins,”
aka “Charly.Africa,”
FNU LNU,
aka “Xplora G,”
UCHENNA OCHIAGHA,
aka “Urch Agu,”
aka “Advanced Mega Plus Ltd,”
NNAMDI THEOJOSEPH DURU,
aka “Duru Theo Joseph
Nnamdi,”
aka “Williams High School,”
aka “Ifytyns,”
ERICSON UCHE OFORKA,
aka “Oforka,”
aka “Eric Oforka,”
MARK IFEANYI CHUKWUOCHA,
aka “Mark Iheanyi
Chukwuocha,”
aka “Chukwu Mark,”
aka “Markife,”
AUGUSTINE NNAMDI,
aka “Nnamdi Augustine,”
aka “Jazz,”
CHIEMEZIE CHRISTOPHER CHILAKA,
aka “Fanta,”
CHARLES OHAJIMKPO,
aka “Giggs,”
aka “Ryan Giggs,”
aka “Charles,”
STANLEY UGOCHUKWU UCHE,
aka “Ugo Law,”
aka “Uche Stanley,”
aka “He is risen.Happy
Easter!,”
CHIKA AUGUSTINE ODIONYENMA,
aka “Tony Augustin
Odionyenma,”
aka “Chika Tony,”
aka “CTA Finance Source
Intl,”
PASCHAL CHIMA OGBONNA,
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aka “Chima,”
aka “Paschal,”
SAMUEL NNAMDI ONWUASOANYA,
aka “Sammy Lee Nnamdi,”
aka “Onwuasoanya Samuel
Nnamdi,”
aka “Enugu Ogo,”
MACWILLIAM CHINONSO CHUKWUOCHA,
aka “ChiBoy,”
EMMANUEL ONYEKA UZOKA,
aka “Emmanuel Mansion,”
aka “Mansion,”
aka “Son of God,”
aka “Ezirim Uzoma,”
JOSHUA ANIEFIOK AWAK,
aka “Joe Awk,”
aka “Kwee Tin Law,”
GEORGE UGOCHUKWU EGWUMBA,
aka “George Ugo,”
aka “Ugo Aunty Scholar,”
UCHECHUKWU SOLOMON EZIRIM,
aka “Uche Nwanne,”
aka “Uche Ezirim,”
AUGUSTINE IFEANYI OKAFOR,
aka “Zero,”
aka “St.Austine,”
aka “Austine,”
aka “Ifeanyichukwu Okafor,”
FNU LNU,
aka “Okay Sam Mal,”
LESLIE N. MBA,
aka “Mystical,”
aka “Nwachinemere Leslie,”
OGOCHUKWU INNOCENT IKEWESI,
aka “Ogoo UK,”
aka “Innocent Ikewesi,”
EMMANUEL UZOMA OGANDU,
aka “Nwachinaemere,”
aka “Uzoma,”
AMARACHUKWU HARLEY ANYANWU,
aka “GodisGod,”
aka “War B,”
BRIGHT IFEANYI AZUBUIKE,
aka “Bright Bauer Azubuike,”
aka “Ifeanyi Jnr,”
EMEKA MOSES NWACHUKWU,
aka “All Man,”
aka “Omalitoto,”
FNU LNU,
aka “Donatus Izunwanne,”
aka “Izunwanne Donatus
Chibuikem,”
aka “Deworlddonmax,”
CHINWENDU KENNETH OSUJI,
aka “Father,”
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EUSEBIUS UGOCHUKWU ONYEKA,
aka “Ugo UK,”
aka “sly19 sly,”
CHIDI ANUNOBI,
aka “Anunobi Chidi,”
aka “Chidioo,”
ANTHONY NWABUNWANNE OKOLO,
aka “Eric West,”
aka “Erci West,”
aka “Code,”
OBINNA CHRISTIAN ONUWA,
aka “Papa Chukwuezugo,”
aka “Obinna Onuwa Abala,”
aka “Obyno Abala,”
CHIJIOKE CHUKWUMA ISAMADE,
aka “Mr CJ,”
aka “CJ,”
LINUS NNAMDI MADUFOR,
aka “Madufor Nnamdi,”
CHRYSAUGONUS NNEBEDUM,
aka “Cris,”
UGOCHUKWU OKEREKE,
aka “Blade,”
aka “Kingsly Cris,”
aka “Okereke Ugochukwu,”
FIDEL LEON ODIMARA,
aka “Fiedel Odimara,”
aka “Ndaa,”
aka “Dee Dutchman,”
KINGSLEY CHINEDU ONUDOROGU,
aka “OBJ,”
DESSI NZENWAH,
aka “Desmond Sage,”
aka “Des Nzenwa,”
aka “Saga Lounge,”
CHIMAROKE OBASI,
aka “Chima Russia”
JAMES CHIGOZIE AGUBE,
aka “Smart,”
aka “Smart Agube,”
aka “Smart Chigozie Agube”
CHIMAOBI UZOZIE OKORIE,
aka “Omaobi,”
aka “Mobility,”
OGOCHUKWU OHIRI,
aka “Ogomegbulam Ohiri,”
aka “Ologbo,”
KENNEDY CHIBUEZE UGWU,
aka “Kennedy David,”
IFEANYICHUKWU OLUWADAMILARE
AGWUEGBO,
aka “B😎😎$$ IFF¥,”
VICTOR IFEANYI CHUKWU,
aka “Ifeannyi Soccer,”
aka “Vic Chux,”
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CHIDI EMMANUEL MEGWA,
aka “Cantr,”
aka “Canta Jr.,”
PRINCEWILL ARINZE DURU,
aka “Arnzi Prince Will,”
aka “Arinze,”
DESMOND IWU,
aka “Desmond Chigozie Iwu,”
aka “Lalaw,”
aka “Odo Desmond,”
ONYEKA VINCENT CHIKA,
aka “Chyco,”
aka “Chika Ejima,”
aka “Vincent Chika Onyeka,”
IFEANYI KINGSLEY MEZIENWA,
aka “Ifeanyi Ali,”
aka “Ifeanyichukwu Mezienwa,”
VICTOR UCHENNA AGUH,
aka “Orch Sod,”
aka “Uche SP,”
aka “Rich Homie Urch,”
KEVIN AMARACHI ESHIMBU,
aka “Humble,”
aka “Humble Amarachukwu,”
aka “Dato Humble,”
VITALIS KELECHI ANOZIE,
aka “Kelechi Vitalis Anozie,”
aka “Kelechi Anozieh,”
aka “Pastor Kel Anozie,”
aka “Pastor Kc,”
aka “Choice,”
WILLIAMS OBIORA AGUNWA,
aka “Don Williams,”
GEORGE CHIMEZIE DIKE,
aka “Chimekros,”
aka “Slim Dad...No...1,”
MUNACHISO KYRIAN UKACHUKWU,
aka “Muna,”
NWANNEBUIKE OSMUND,
aka “Osmund Nwannebuike,”
aka “Olivite,”
aka “Nikky Bro.,”
CHIDIEBERE FRANKLIN NWANGWU,
aka “Frank Chidi,”
aka “Franklin Nwangwu,”
aka “Agogo,”
DAMIAN UCHECHUKWU AJAH,
aka “Uche Ajah,”
aka “Ajah Damian Uchechukwu,”
aka “Uchechukwu Demian Ajah,”
EMEKA P. EJIOFOR,
aka “Ejiofor Emeka,”
LAWRENCE CHUKWUMA UBASINEKE,
aka “Ubasineke Chuks,”
aka “Chukwuma Ubasineke,”
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CHINEDU BRIGHT IBETO,
aka “Doggy,”
aka “Doggy Lucino,”
VALENTINE AMARACHI NWANEGWO,
aka “Satis,”
aka “Satis Amarachi Satis,”
EMMANUEL CHIDIEBERE DIKE,
aka “Emmanet,”
JEREMIAH UTIEYIN EKI,
aka “Uti,”
CHINAKA DAVIDSON IWUOHA,
aka “Tmrw Afrika Will Wake
Up,”
aka “Cookie,”
aka “All Africa Media
Network,”
CHIMA DARLINGTON DURU,
aka “Kajad,”
aka “Kajad Jesus,”
IKENNA CHRISTIAN IHEJIUREME,
aka “Piper,”
aka “Am Happy!,”
OBI ONYEDIKA MADEKWE,
aka “Odu Investment,”

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Defendants.
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The Grand Jury charges:

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INTRODUCTORY ALLEGATIONS

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At times relevant to this Indictment:
A.

Defendants
1.

Defendants VALENTINE IRO, also known as (“aka”) “Iro

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Enterprises,” aka “Valentine Obinna Iro,” aka “Obinna Iro,” aka

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“Obinna Nassa” (“IRO”); JERRY ELO IKOGHO, aka “J Man” (“IKOGHO”);

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IZUCHUKWU KINGSLEY UMEJESI, aka “Kingsley Umejesi,” aka “Armenian

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Man,” aka “Kingsley LA,” aka “Izuking Aka Aku” (“UMEJESI”); ADEGOKE

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MOSES OGUNGBE, aka “P & P Motors,” aka “Pp” (“OGUNGBE”); ALBERT LEWIS

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CATHEY, aka “Alb,” aka “Abert Jag,” aka “Al” (“CATHEY”); TITYAYE

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MARINA MANSBANGURA, aka “Tityaye Igbokwe,” aka “Marina Mansour,” aka

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“Marina Mansaray,” aka “Marina Tityaye Mans Bangura” (“MANSBANGURA”);

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EKENE AUGUSTINE EKECHUKWU, aka “Ogedi Power,” aka “Power”
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(“EKECHUKWU”); COLLINS NNAEMEKA OJIMBA, aka “Collins Emeka Ojimba,”

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aka “Ojimba Collins,” aka “Charly.Africa” (“OJIMBA”); GEORGE

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UGOCHUKWU EGWUMBA, aka “George Ugo,” aka “Ugo Aunty Scholar”

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(“EGWUMBA”); VICTOR IFEANYI CHUKWU, aka “Ifeannyi Soccer,” aka “Vic

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Chux” (“CHUKWU”); CHIDI EMMANUEL MEGWA, aka “Cantr,” aka “Canta Jr.”

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(“MEGWA”); and NWANNEBUIKE OSMUND, aka “Osmund Nwannebuike,” aka

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“Olivite,” aka “Nikky Bro.” (“OSMUND”), resided within the Central

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District of California.

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2.

Defendant CHUKWUDI CHRISTOGUNUS IGBOKWE, aka “Christogunus

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C. Igbokwe,” aka “Chris Kudon,” aka “Atete,” aka “Still Kudon”

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(“IGBOKWE”) resided in Nigeria until on or about January 17, 2017,

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and thereafter resided within the Central District of California.

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3.

Defendant CHUKWUDI COLLINS AJAEZE, aka “Thank You Jesus”

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(“AJAEZE”) resided in Nigeria until on or about June 19, 2017, and

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thereafter resided within the Central District of California.

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4.

Defendant CHUKS EROHA, aka “Chuks Nassa Iro,” aka “Nassa,”

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aka “Prince Chuddy,” aka “Nurse Chuddy” (“EROHA”) resided within the

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Central District of California until on or about July 29, 2017, and

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thereafter resided outside the United States.

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Defendant MACWILLIAM CHINONSO CHUKWUOCHA, aka “ChiBoy”

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(“MACWILLIAM CHUKWUOCHA”); EMMANUEL ONYEKA UZOKA, aka “Emmanuel

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Mansion,” aka “Mansion,” aka “Son of God,” aka “Ezirim Uzoma”

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(“UZOKA”); CHIJIOKE CHUKWUMA ISAMADE, aka “Mr CJ,” aka “CJ”

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(“ISAMADE”);

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aka “Dee Dutchman” (“ODIMARA”); KENNEDY CHIBUEZE UGWU, aka “Kennedy

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David” (“UGWU”); IFEANYICHUKWU OLUWADAMILARE AGWUEGBO, aka “B😎😎$$

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IFF¥” (“AGWUEGBO”); PRINCEWILL ARINZE DURU, aka “Arnzi Prince Will,”

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aka “Arinze” (“P. DURU”); and MUNACHISO KYRIAN UKACHUKWU, aka “Muna”

FIDEL LEON ODIMARA, aka “Fiedel Odimara,” aka “Ndaa,”

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(“UKACHUKWU”) resided in the United States, outside the Central

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District of California.

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CHIEMEZIE CHRISTOPHER CHILAKA, aka “Fanta” (“CHILAKA”)

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resided within the United States, outside the Central District of

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California, between on or about January 17, 2017 and March 18, 2017,

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and otherwise resided outside of the United States.

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7.

Defendant JOSHUA ANIEFIOK AWAK, aka “Joe Awk,” aka “Kwee

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Tin Law” (“AWAK”) resided in Nigeria until on or about August 25,

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2018, and thereafter resided within the Central District of

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California.
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Defendants First Name Unknown (“FNU”) Last Name Unknown

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(“LNU”), aka “Xplora G” (“XPLORA G”); UCHENNA OCHIAGHA, aka “Urch

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Agu,” aka “Advanced Mega Plus Ltd” (“OCHIAGHA”); NNAMDI THEOJOSEPH

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DURU, aka ““Duru Theo Joseph Nnamdi,” aka “Williams High School,” aka

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“Ifytyns” (“N. DURU”); ERICSON UCHE OFORKA, aka “Oforka,” aka “Eric

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Oforka” (“OFORKA”);

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Chukwuocha,” aka “Chukwu Mark,” aka “Markife” (“MARK CHUKWUOCHA”);

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AUGUSTINE NNAMDI, aka “Nnamdi Augustine,” aka “Jazz” (“NNAMDI”);

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CHARLES OHAJIMKPO, aka “Giggs,” aka “Ryan Giggs,” aka “Charles”

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(“OHAJIMKPO”); STANLEY UGOCHUKWU UCHE, aka “Ugo Law,” aka “Uche

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Stanley,” aka “He is risen.Happy Easter!” (“UCHE”); CHIKA AUGUSTINE

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ODIONYENMA, aka “Tony Augustin Odionyenma,” aka “Chika Tony,” aka

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“CTA Finance Source Intl” (“ODIONYENMA”); PASCHAL CHIMA OGBONNA, aka

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“Chima,” aka “Paschal” (“OGBONNA”); SAMUEL NNAMDI ONWUASOANYA, aka

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“Sammy Lee Nnamdi,” aka “Onwuasoanya Samuel Nnamdi,” aka “Enugu Ogo”

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(“ONWUASOANYA”); UCHECHUKWU SOLOMON EZIRIM, aka “Uche Nwanne,” aka

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“Uche Ezirim” (“EZIRIM”); AUGUSTINE IFEANYI OKAFOR, aka “Zero,” aka

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“St.Austine,” aka “Austine,” aka “Ifeanyichukwu Okafor” (“OKAFOR”);

MARK IFEANYI CHUKWUOCHA, aka “Mark Iheanyi

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FNU LNU, aka “Okay Sam Mal” (“SAM MAL”); LESLIE N. MBA, aka

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“Mystical,” aka “Nwachinemere Leslie” (“MBA”); OGOCHUKWU INNOCENT

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IKEWESI, aka “Ogoo UK,” aka “Innocent Ikewesi” (“IKEWESI”); EMMANUEL

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UZOMA OGANDU, aka “Nwachinaemere,” aka “Uzoma” (“OGANDU”);

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AMARACHUKWU HARLEY ANYANWU, aka “GodisGod,” aka “War B” (“ANYANWU”);

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BRIGHT IFEANYI AZUBUIKE, aka “Bright Bauer Azubuike,” aka “Ifeanyi

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Jnr” (“AZUBUIKE”); EMEKA MOSES NWACHUKWU, aka “All Man,” aka

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“Omalitoto” (“NWACHUKWU”); FNU LNU aka “Donatus Izunwanne,” aka

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“Izunwanne Donatus Chibuikem,” aka “Deworlddonmax” (“IZUNWANNE”);

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CHINWENDU KENNETH OSUJI, aka “Father” (“OSUJI”); EUSEBIUS UGOCHUKWU

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ONYEKA, aka “Ugo UK,” aka “sly19 sly” (“ONYEKA”); CHIDI ANUNOBI, aka

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“Anunobi Chidi,” aka “Chidioo” (“ANUNOBI”); ANTHONY NWABUNWANNE

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OKOLO, aka “Eric West,” aka “Erci West,” aka “Code” (“OKOLO”); OBINNA

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CHRISTIAN ONUWA, aka “Papa Chukwuezugo,” aka “Obinna Onuwa Abala,”

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aka “Obyno Abala” (“ONUWA”); LINUS NNAMDI MADUFOR, aka “Madufor

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Nnamdi” (“MADUFOR”); CHRYSAUGONUS NNEBEDUM,

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UGOCHUKWU OKEREKE, aka “Blade,” aka “Kingsly Cris,” aka “Okereke

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Ugochukwu” (“OKEREKE”); KINGSLEY CHINEDU ONUDOROGU, aka “OBJ”

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(“ONUDOROGU”); DESSI NZENWAH, aka “Desmond Sage,” aka “Des Nzenwa,”

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aka “Saga Lounge” (“NZENWAH”); CHIMAROKE OBASI, aka “Chima Russia”

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(“OBASI”); JAMES CHIGOZIE AGUBE, aka “Smart,” aka “Smart Agube,” aka

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“Smart Chigozie Agube” (“AGUBE”); CHIMAOBI UZOZIE OKORIE, aka

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“Omaobi,” aka “Mobility” (“OKORIE”); OGOCHUKWU OHIRI, aka

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“Ogomegbulam Ohiri,” aka “Ologbo” (“OHIRI”); DESMOND IWU, aka

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“Desmond Chigozie Iwu,” aka “Lalaw,” aka “Odo Desmond” (“IWU”);

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ONYEKA VINCENT CHIKA, aka “Chyco,” aka “Chika Ejima,” aka “Vincent

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Chika Onyeka” (“CHIKA”); IFEANYI KINGSLEY MEZIENWA, aka “Ifeanyi

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Ali,” aka “Ifeanyichukwu Mezienwa” (“MEZIENWA”); VICTOR UCHENNA AGUH,
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aka “Cris” (“NNEBEDUM”);

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aka “Orch Sod,” aka “Uche SP,” aka “Rich Homie Urch” (“AGUH”); KEVIN

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AMARACHI ESHIMBU, aka “Humble,” aka “Humble Amarachukwu,” aka “Dato

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Humble” (“ESHIMBU”); VITALIS KELECHI ANOZIE, aka “Kelechi Vitalis

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Anozie,” aka “Kelechi Anozieh,” aka “Pastor Kel Anozie,” aka “Pastor

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Kc,” aka “Choice” (“ANOZIE”); WILLIAMS OBIORA AGUNWA, aka “Don

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Williams” (“AGUNWA”); GEORGE CHIMEZIE DIKE,

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“Slim Dad...No...1” (“G. DIKE”); CHIDIEBERE FRANKLIN NWANGWU, aka

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“Frank Chidi,” aka “Franklin Nwangwu,” aka “Agogo” (“NWANGWU”);

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DAMIAN UCHECHUKWU AJAH, aka “Uche Ajah,” aka “Ajah Damian

aka “Chimekros,” aka

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Uchechukwu,” aka “Uchechukwu Demian Ajah” (“AJAH”); EMEKA P. EJIOFOR,

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aka “Ejiofor Emeka” (“EJIOFOR”); LAWRENCE CHUKWUMA UBASINEKE, aka

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“Ubasineke Chuks,” aka “Chukwuma Ubasineke” (“UBASINEKE”); CHINEDU

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BRIGHT IBETO, aka “Doggy,” aka “Doggy Lucino” (“IBETO”); VALENTINE

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AMARACHI NWANEGWO, aka “Satis,” aka “Satis Amarachi Satis”

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(“NWANEGWO”); EMMANUEL CHIDIEBERE DIKE, aka “Emmanet” (“E. DIKE”);

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JEREMIAH UTIEYIN EKI, aka “Uti” (“EKI”); CHINAKA DAVIDSON IWUOHA, aka

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“Tmrw Afrika Will Wake Up,” aka “Cookie,” aka “All Africa Media

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Network” (“IWUOHA”); CHIMA DARLINGTON DURU, aka “Kajad,” aka “Kajad

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Jesus” (“C. DURU”); and IKENNA CHRISTIAN IHEJIUREME, aka “Piper,”

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aka “Am Happy!” (“IHEJIUREME”) resided outside of the United States.
9.

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OBI ONYEDIKA MADEKWE, aka “Odu Investment” (“MADEKWE”)

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resided in the United States until on or about April 18, 2017, and

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thereafter resided outside the United States.

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B.

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Unindicted Coconspirators
10.

Unindicted Coconspirator #1 (“UICC 1”), UICC 2, UICC 7,

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UICC 9, UICC 10, UICC 11, UICC 12, UICC 13, UICC 14, UICC 15, UICC

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16, UICC 17, UICC 18, UICC 20, UICC 21, UICC 22, UICC 23, and UICC 24

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resided within the Central District of California.
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2

11.

UICC 8 and UICC 19 resided in the United States, outside

the Central District of California.

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12.

UICC 3, UICC 4, UICC 5, UICC 6, UICC 25, and 26 resided

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outside of the United States.

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C.

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Financial Institutions
13.

At all times relevant to this Indictment, Bank of America

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N.A. (“BOA”), BBVA Compass Bancshares, Inc. (“Compass Bank”), CalCom

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Federal Credit Union (“CalCom FCU”), Capital One Bank (“Capital

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One”), Citibank N.A. (“Citibank”), Citizens Financial Group

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(“Citizens Bank”), Comerica Bank (“Comerica”), J.P. Morgan Chase N.A.

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(“Chase”), PNC Bank, Regions Financial Corporation (“Regions Bank”)

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SunTrust Bank (“SunTrust”), TD Bank N.A. (“TD Bank”), US Bank N.A.

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(“US Bank”), and Wells Fargo Bank, N.A. (“Wells Fargo”) were

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federally insured financial institutions.

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D.

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Terminology
14.

Business email compromise (“BEC”) frauds may occur when a

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hacker gains unauthorized access to a business email account, blocks

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or redirects communications to and/or from the email account, and

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then uses the compromised email account or a separate fraudulent

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email account to communicate with personnel from a victim company,

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attempting to trick them into making an unauthorized wire transfer.

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15.

Escrow fraud is a variation of a BEC fraud scheme, in which

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a hacker may gain unauthorized access to the email account of an

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escrow company or real estate agent, and then communicate with an

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unsuspecting person who is seeking to purchase property, directing

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that person to make a down-payment for purchase of property to a

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fraudulent bank account, rather than the legitimate bank account of

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an escrow company.
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16.

Romance scams target persons looking for romantic partners

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or friendship on dating websites and other social media platforms.

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The scammers may create profiles using fictitious or fake names,

4

locations, images, and personas, allowing the scammers to cultivate

5

relationships with prospective romance scam victims.

6

convinced to provide money or gifts to the scammers, or may be asked

7

to conduct transactions on behalf of the scammers.

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
12

Victims may be

 1
COUNT ONE
2
[18 U.S.C. § 1956(h)]
3
[ALL DEFENDANTS]
4
17.

The Grand Jury re-alleges and incorporates paragraphs 1

5
through 16 of the Introductory Allegations of this Indictment here.
6
A.

OBJECTS OF THE CONSPIRACY

7
18.

Beginning on a date unknown to the Grand Jury, but no later

8
than October 7, 2014, and continuing through an unknown date, but no
9
earlier than on or about May 2, 2018, in Los Angeles County, within
10
the Central District of California, and elsewhere, defendants IRO,
11
IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY, MANSBANGURA, AJAEZE,
12
EKECHUKWU, EROHA, OJIMBA, XPLORA G, OCHIAGHA, N. DURU, OFORKA, MARK
13
CHUKWUOCHA, NNAMDI, CHILAKA, OHAJIMKPO, UCHE, ODIONYENMA, OGBONNA,
14
ONWUASOANYA, MACWILLIAM CHUKWUOCHA, UZOKA, AWAK, EGWUMBA, EZIRIM,
15
OKAFOR, SAM MAL, MBA, IKEWESI, OGANDU, ANYANWU, AZUBUIKE, NWACHUKWU,
16
IZUNWANNE, OSUJI, ONYEKA, ANUNOBI, OKOLO, ONUWA, ISAMADE, MADUFOR,
17
NNEBEDUM, OKEREKE, ODIMARA, ONUDOROGU, NZENWAH, OBASI, AGUBE, OKORIE,
18
OHIRI, UGWU, AGWUEGBO, CHUKWU, MEGWA, P. DURU, IWU, CHIKA, MEZIENWA,
19
AGUH, ESHIMBU, ANOZIE, AGUNWA, G. DIKE, UKACHUKWU, OSMUND, NWANGWU,
20
AJAH, EJIOFOR, UBASINEKE, IBETO, NWANEGWO, E. DIKE, EKI, IWUOHA,
21
C. DURU, IHEJIUREME, and MADEKWE, together with UICC 1 through UICC
22
26 and others known and unknown to the Grand Jury, knowingly
23
conspired:
24
a.

to conduct and attempt to conduct, financial

25
transactions, affecting interstate and foreign commerce, knowing that
26
the property involved in the financial transactions represented the
27
proceeds of some form of unlawful activity, which, in fact, involved
28
13

 1

the proceeds of specified unlawful activity — namely, wire fraud, in

2

violation of Title 18, United States Code, Section 1343; mail fraud,

3

in violation of Title 18, United States Code, Section 1341; and bank

4

fraud, in violation of Title 18, United States Code, Section 1344(2)

5

— and knowing that the transactions were designed in whole and in

6

part to conceal and disguise the nature, location, source, ownership,

7

and control of the proceeds, in violation of Title 18, United States

8

Code, Section 1956(a)(1)(B)(i);

9

b.

to transport, transmit, and transfer, and attempt to

10

transport, transmit, and transfer, funds from a place in the United

11

States to a place outside of the United States, knowing that the

12

property involved in the financial transactions represented the

13

proceeds of some form of unlawful activity, and which property was,

14

in fact, the proceeds of specified unlawful activity — namely, wire

15

fraud, in violation of Title 18, United States Code, Section 1343;

16

mail fraud, in violation of Title 18, United States Code, Section

17

1341; and bank fraud, in violation of Title 18, United States Code,

18

Section 1344(2) — and knowing that the transactions were designed in

19

whole and in part to conceal and disguise the nature, location,

20

source, ownership, and control of the proceeds, in violation of Title

21

18, United States Code, Section 1956(a)(2)(B)(i); and

22

c.

to engage and attempt to engage in monetary

23

transactions involving criminally derived property of a value greater

24

than $10,000, affecting interstate and foreign commerce, which was

25

derived from specified unlawful activity — namely, wire fraud, in

26

violation of Title 18, United States Code, Section 1343; mail fraud,

27

in violation of Title 18, United States Code, Section 1341; and bank

28

fraud, in violation of Title 18, United States Code, Section 1344(2)
14

 1

— and knowing that the funds represented the proceeds of some form of

2

unlawful activity, in violation of Title 18, United States Code,

3

Section 1957.

4

B.

MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE

5

ACCOMPLISHED

6

19.

The objects of the conspiracy were to be accomplished, in

7

substance, as follows:

8

a.

Defendants UMEJESI, OGUNGBE, EKECHUKWU, XPLORA G,

9

OCHIAGHA, N. DURU, OFORKA, MARK CHUKWUOCHA, NNAMDI, CHILAKA,

10

OHAJIMKPO, UCHE, ODIONYENMA, OGBONNA, ONWUASOANYA, MACWILLIAM

11

CHUKWUOCHA, UZOKA, AWAK, EGWUMBA, EZIRIM, OKAFOR, SAM MAL, MBA,

12

IKEWESI, OGANDU, ANYANWU, AZUBUIKE, NWACHUKWU, IZUNWANNE, OSUJI,

13

ONYEKA, ANUNOBI, OKOLO, ONUWA, ISAMADE, MADUFOR, NNEBEDUM, OKEREKE,

14

ODIMARA, ONUDOROGU, NZENWAH, OBASI, AGUBE, OKORIE, OHIRI, UGWU,

15

AGWUEGBO, CHUKWU, MEGWA, IWU, CHIKA, MEZIENWA, AGUH, ESHIMBU, ANOZIE,

16

AGUNWA, G. DIKE, UKACHUKWU, OSMUND, NWANGWU, AJAH, EJIOFOR,

17

UBASINEKE, IBETO, NWANEGWO, E. DIKE, EKI, IWUOHA, C. DURU, and

18

IHEJIUREME would ask defendants IRO, IGBOKWE, and EROHA for a bank

19

account or money service account into which they could fraudulently

20

induce a victim to deposit funds from a BEC fraud, escrow fraud,

21

romance scam, or other fraudulent scheme.

22

b.

In response to such a request, defendants IRO,

23

IGBOKWE, and EROHA would (i) select a bank account or money service

24

account that had previously been opened in order to receive

25

fraudulently-obtained funds, which could receive the fraudulently-

26

obtained funds; (ii) request that a coconspirator, including

27

defendants UMEJESI, CATHEY, MANSBANGURA, AJAEZE, EKECHUKWU, OJIMBA,

28

ISAMADE, MEGWA, IKEWESI, ONYEKA, NZENWAH, P. DURU, and OBASI, provide
15

 1

the account information for a bank account or money service account,

2

which could receive the fraudulently-obtained funds; or (iii) cause a

3

bank account or money service account to be opened, which could

4

receive the fraudulently-obtained funds.

5

i.

For a bank account that was to be opened,

6

defendants IRO and IGBOKWE would request that a coconspirator,

7

including defendants UMEJESI, CATHEY, MANSBANGURA, AJAEZE, EKECHUKWU,

8

OJIMBA, ISAMADE, and P. DURU, open or cause to be opened a bank

9

account, which these coconspirators and others acting at their

10

direction would do through use of false or fraudulent pretenses,

11

representations, and promises, and concealment of material facts.

12

ii.

For a bank account opened in a business name,

13

defendants IRO, IGBOKWE, EROHA, UMEJESI, CATHEY, MANSBANGURA, AJAEZE,

14

EKECHUKWU, OJIMBA, AWAK, ISAMADE, and P. DURU would file, or would

15

cause to be filed, a false and fraudulent Fictitious Business Name

16

Statement at the Los Angeles County Registrar-Recorder/County Clerk’s

17

Office.

18

c.

Defendants IRO, IGBOKWE, and EROHA would send

19

defendants UMEJESI, OGUNGBE, EKECHUKWU, XPLORA G, OCHIAGHA, N. DURU,

20

OFORKA, MARK CHUKWUOCHA, NNAMDI, CHILAKA, OHAJIMKPO, UCHE,

21

ODIONYENMA, OGBONNA, ONWUASOANYA, MACWILLIAM CHUKWUOCHA, UZOKA, AWAK,

22

EGWUMBA, EZIRIM, OKAFOR, SAM MAL, MBA, IKEWESI, OGANDU, ANYANWU,

23

AZUBUIKE, NWACHUKWU, IZUNWANNE, OSUJI, ONYEKA, ANUNOBI, OKOLO, ONUWA,

24

ISAMADE, MADUFOR, NNEBEDUM, OKEREKE, ODIMARA, ONUDOROGU, NZENWAH,

25

OBASI, AGUBE, OKORIE, OHIRI, UGWU, AGWUEGBO, CHUKWU, MEGWA, IWU,

26

CHIKA, MEZIENWA, AGUH, ESHIMBU, ANOZIE, AGUNWA, G. DIKE, UKACHUKWU,

27

OSMUND, NWANGWU, AJAH, EJIOFOR, UBASINEKE, IBETO, NWANEGWO, E. DIKE,

28

EKI, IWUOHA, C. DURU, and IHEJIUREME the account information for the
16

 1

bank account or money service account that could be used to receive

2

fraudulently-obtained funds.

3

IRO, IGBOKWE, and EROHA would, at a minimum, send the account number

4

and the routing number.

5

d.

For such a bank account, defendants

Defendants IRO, IGBOKWE, and EROHA would come to an

6

agreement with defendants UMEJESI, OGUNGBE, EKECHUKWU, XPLORA G,

7

OCHIAGHA, N. DURU, OFORKA, MARK CHUKWUOCHA, NNAMDI, CHILAKA,

8

OHAJIMKPO, UCHE, ODIONYENMA, OGBONNA, ONWUASOANYA, MACWILLIAM

9

CHUKWUOCHA, UZOKA, AWAK, EGWUMBA, EZIRIM, OKAFOR, SAM MAL, MBA,

10

IKEWESI, OGANDU, ANYANWU, AZUBUIKE, NWACHUKWU, IZUNWANNE, OSUJI,

11

ONYEKA, ANUNOBI, OKOLO, ONUWA, ISAMADE, MADUFOR, NNEBEDUM, OKEREKE,

12

ODIMARA, ONUDOROGU, NZENWAH, OBASI, AGUBE, OKORIE, OHIRI, UGWU,

13

AGWUEGBO, CHUKWU, MEGWA, IWU, CHIKA, MEZIENWA, AGUH, ESHIMBU, ANOZIE,

14

AGUNWA, G. DIKE, UKACHUKWU, OSMUND, NWANGWU, AJAH, EJIOFOR,

15

UBASINEKE, IBETO, NWANEGWO, E. DIKE, EKI, IWUOHA, C. DURU, and

16

IHEJIUREME regarding the percentage of the fraudulently-obtained

17

funds that defendants IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY,

18

MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA, ISAMADE, MEGWA, and P.

19

DURU would receive for their receiving and laundering services.

20

e.

Defendants UMEJESI, OGUNGBE, EKECHUKWU, XPLORA G,

21

OCHIAGHA, N. DURU, OFORKA, MARK CHUKWUOCHA, NNAMDI, CHILAKA,

22

OHAJIMKPO, UCHE, ODIONYENMA, OGBONNA, ONWUASOANYA, MACWILLIAM

23

CHUKWUOCHA, UZOKA, AWAK, EGWUMBA, EZIRIM, OKAFOR, SAM MAL, MBA,

24

IKEWESI, OGANDU, ANYANWU, AZUBUIKE, NWACHUKWU, IZUNWANNE, OSUJI,

25

ONYEKA, ANUNOBI, OKOLO, ONUWA, ISAMADE, MADUFOR, NNEBEDUM, OKEREKE,

26

ODIMARA, ONUDOROGU, NZENWAH, OBASI, AGUBE, OKORIE, OHIRI, UGWU,

27

AGWUEGBO, CHUKWU, MEGWA, IWU, CHIKA, MEZIENWA, AGUH, ESHIMBU, ANOZIE,

28

AGUNWA, G. DIKE, UKACHUKWU, OSMUND, NWANGWU, AJAH, EJIOFOR,
17

 1

UBASINEKE, IBETO, NWANEGWO, E. DIKE, EKI, IWUOHA, C. DURU, and

2

IHEJIUREME, or their coconspirators, would, through false or

3

fraudulent pretenses, representations, and promises, and concealment

4

of material facts, persuade a victim to deposit, wire, or transfer

5

funds into a bank account or money service accounts identified by

6

defendants IRO, IGBOKWE, and EROHA.

7

f.

Defendants and coconspirators would also make false or

8

fraudulent statements, representations, and promises, and conceal

9

material facts, in order to avoid discovery of the fraudulent nature

10
11

of the deposit, wire, or transfer.
g.

Defendants IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE,

12

CATHEY, MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA, ISAMADE,

13

MEGWA, and P. DURU would withdraw, and attempt to withdraw, the

14

fraudulently-obtained funds from a bank account or money service

15

account, including through cash withdrawals, wire transfers, teller

16

transfers, check cashing, and deposits into further accounts used by

17

or under the control of defendants IRO, IGBOKWE, IKOGHO, UMEJESI,

18

OGUNGBE, CATHEY, MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA,

19

ISAMADE, MEGWA, and P. DURU, and other coconspirators working at

20

their direction, before the victim became aware of the fraudulent

21

nature of the transactions, so as to obtain the money and so as to

22

conceal and disguise the nature, location, source, ownership and

23

control of the proceeds.

24

h.

When a bank would question the source of the funds or

25

nature of a transaction, defendants IRO, IGBOKWE, IKOGHO, UMEJESI,

26

OGUNGBE, CATHEY, MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA,

27

ISAMADE, MEGWA, and P. DURU, and others acting at their direction,

28

would lie and make material omissions about their ownership of and
18

 1

entitlement to the funds, or the source of the funds, so as to obtain

2

the money and so as to avoid detection and conceal the fact that the

3

funds were fraudulently obtained from a victim.

4

i.

Defendants IRO, IGBOKWE, UMEJESI, CATHEY, and

5

MANSBANGURA would, on occasion, deposit funds, or cause funds to be

6

deposited, into the bank account of an illicit and unlicensed money

7

exchanger, including defendants IKOGHO, OGUNGBE, and MADEKWE, who

8

would then transfer other funds from Nigerian bank accounts that they

9

controlled to the Nigerian bank accounts of coconspirators.

10

Alternatively, defendants IRO and IGBOKWE would, on occasion, direct

11

UICC 3, UICC 4, UICC 5, and UICC 6 to transfer other funds from

12

Nigerian bank accounts that they controlled to the Nigerian bank

13

accounts of coconspirators.

14

C.

15

OVERT ACTS
20.

In furtherance of the conspiracy, and to accomplish its

16

objects, defendants IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY,

17

MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA, XPLORA G, OCHIAGHA, N.

18

DURU, OFORKA, MARK CHUKWUOCHA, NNAMDI, CHILAKA, OHAJIMKPO, UCHE,

19

ODIONYENMA, OGBONNA, ONWUASOANYA, MACWILLIAM CHUKWUOCHA, UZOKA, AWAK,

20

EGWUMBA, EZIRIM, OKAFOR, SAM MAL, MBA, IKEWESI, OGANDU, ANYANWU,

21

AZUBUIKE, NWACHUKWU, IZUNWANNE, OSUJI, ONYEKA, ANUNOBI, OKOLO, ONUWA,

22

ISAMADE, MADUFOR, NNEBEDUM, OKEREKE, ODIMARA, ONUDOROGU, NZENWAH,

23

OBASI, AGUBE, OKORIE, OHIRI, UGWU, AGWUEGBO, CHUKWU, MEGWA, P. DURU,

24

IWU, CHIKA, MEZIENWA, AGUH, ESHIMBU, ANOZIE, AGUNWA, G. DIKE,

25

UKACHUKWU, OSMUND, NWANGWU, AJAH, EJIOFOR, UBASINEKE, IBETO,

26

NWANEGWO, E. DIKE, EKI, IWUOHA, C. DURU, IHEJIUREME, and MADEKWE,

27

together with others known and unknown to the Grand Jury, on or about

28

the dates set forth below, committed and caused to be committed
19

 1

various overt acts, in the Central District of California and

2

elsewhere, including, but not limited to, the following:

3
4

Victim M.S.
Overt Act No. 1:

On or about September 3, 2015, defendant IRO

5

sent defendant OGBONNA account information, including the account

6

number and the routing number, for a Chase checking account ending in

7

9837 of defendant IRO, doing business as (“dba”) “VOI Enterprises,”

8

in Carson, California (“Chase 9837 Account”), with the instruction to

9

have victim M.S. include the following payment information in the

10

notes of the wire transfer:

11

Overt Act No. 2:

“INV: VOI53753.”

On or about September 3, 2015, an unknown

12

coconspirator fraudulently induced M.S. to send a wire transfer of

13

approximately $23,000 from her BOA account in Monterey Park,

14

California to IRO’s Chase 9837 Account, with the wire transfer notes

15

reading “OTHER INVOICE NO. VOI53753.”

16

Overt Act No. 3:

On or about September 4, 2015, defendant IRO

17

withdrew approximately $14,000 from the Chase 9837 Account and wrote

18

on the withdrawal slip, “for Lexus RX330 and RX300.”

19

Overt Act No. 4:

On or about September 4, 2015, defendant IRO

20

wrote a check to a relative for approximately $1,500 from the Chase

21

9837 Account, and wrote on the memo line, “2002 Nissan Optima.”

22

Overt Act No. 5:

On or about September 8, 2015, an unknown

23

coconspirator fraudulently induced M.S. to send a wire transfer of

24

approximately $46,500 from her BOA account in Monterey Park,

25

California to defendant IRO’s Chase 9837 Account.

26

Overt Act No. 6:

On or about September 8, 2015, defendant IRO

27

withdrew approximately $8,000 from the Chase 9837 Account and wrote

28

on the withdrawal slip, “Mercedes 2011 and Lexis RX 350 2008.”
20

 1

Overt Act No. 7:

On or about September 10, 2015, defendant

2

IRO withdrew approximately $30,000 from the Chase 9837 Account and

3

wrote on the withdrawal slip, “for Acura MDX 2007.”

4
5
6

Overt Act No. 8:

On or about September 10, 2015, defendant

IRO withdrew approximately $9,000 from the Chase 9837 Account.
Overt Act No. 9:

On or about September 10, 2015, an unknown

7

coconspirator fraudulently induced M.S. to send a wire transfer of

8

approximately $4,700 from her BOA account in Monterey Park,

9

California to defendant IRO’s Chase 9837 Account.

10

Overt Act No. 10:

On or about September 11, 2015, defendant

11

IRO wrote a check to an acquaintance for approximately $7,700, and

12

wrote on the memo line, “Camry 207 and Camry 05.”

13

Overt Act No. 11:

On or about September 14, 2015, defendant

14

IRO sent OGBONNA the instruction to have victim M.S. include the

15

following payment information in the notes of the wire transfer:

16

“Invoice number: VOI00462 R MODEL 89.”

17

Overt Act No. 12:

On or about September 14, 2015, an unknown

18

coconspirator fraudulently induced M.S. to send a wire transfer of

19

approximately $17,000 from her BOA account in Monterey Park,

20

California to defendant IRO’s Chase 9837 Account, with a wire

21

transfer note reading “INVOICE NO. VOI 00462 R MODEL 89.”

22
23
24
25
26
27

Overt Act No. 13:

On or about September 17, 2015, defendant

IRO withdrew approximately $10,000 from the Chase 9837 Account.
Overt Act No. 14:

On or about September 17, 2015, defendant

IRO withdrew approximately $20,000 from the Chase 9837 Account.
Overt Act No. 15:

On or about September 17, 2015, defendant

IRO withdrew approximately $5,000 from the Chase 9837 Account.

28
21

 1
2

Victim Company 2
Overt Act No. 16:

On or about February 12, 2016, an unknown

3

coconspirator fraudulently induced Victim Company 2 to send a wire

4

transfer of approximately $186,686 from its United Bank of Africa

5

account to defendant IRO’s Chase 9837 Account.

6

Overt Act No. 17:

On or about February 12, 2016, defendant IRO

7

transferred approximately $188,600 from the Chase 9837 Account to a

8

Chase savings account ending in 0820 of defendant IRO, dba “VOI

9

Enterprises,” in Carson, California (“Chase 0820 Account”).

10

Overt Act No. 18:

On or about February 12, 2016, defendant IRO

11

transferred approximately $161,700 from the Chase 0820 Account to the

12

Chase 9837 Account.

13

Overt Act No. 19:

On or about February 16, 2016, defendant IRO

14

sent a wire transfer of approximately $132,950 from the Chase 9837

15

Account to a Wells Fargo account ending in 6061 of defendant IRO, dba

16

“Irva Auto Sales & Equip Broker LLC,” in Carson, California (“Wells

17

Fargo 6061 Account”), with a wire transfer note reading “Invoice:

18

Mack Rd Model 2010 X.”

19

Overt Act No. 20:

On or about February 16, 2016, defendant IRO

20

sent a wire transfer of approximately $28,670 from the Chase 9837

21

Account to the bank account ending in 3107 of UICC 7 at CalCom FCU,

22

in Torrance, California (“CalCom 3107 Account”), with the wire

23

transfer note reading “Menhien Auction On Wednesday.”

24

Overt Act No. 21:

On or about February 16, 2016, UICC 7

25

attempted to send a wire transfer of approximately $27,500 from the

26

CalCom 3107 Account to the Wells Fargo 6061 Account, with the wire

27

transfer note reading “Invoice for IRVA4646.”

28
22

 1

Overt Act No. 22:

On or about February 16, 2016, defendant IRO

2

sent a wire transfer of approximately $50,000 from the Wells Fargo

3

6061 Account to a BOA account ending in 1824.

4
5
6

Overt Act No. 23:

On or about February 16, 2016, defendant IRO

withdrew approximately $50,000 from the Wells Fargo 6061 Account.
Overt Act No. 24:

On or about February 18, 2016, defendant IRO

7

sent a wire transfer of approximately $30,500 from the Chase 9837

8

Account to a Chase account ending in 1279 of UICC 8.

9
10

Victim R.B.
Overt Act No. 25:

On or about March 31, 2016, an unknown

11

coconspirator fraudulently induced R.B. to send a wire transfer of

12

approximately $18,000 from her Wells Fargo account in Panama City

13

Beach, Florida, to a bank account at Comerica ending in 2663 of

14

defendant IRO, dba “IRVA Auto Sales & Equip Broker LLC,” in Carson,

15

California (“Comerica 2663 Account”).

16

Overt Act No. 26:

On or about March 31, 2016, defendant

17

ODIONYENMA emailed to defendant IRO a photograph of the wire transfer

18

request for approximately $18,000 submitted by R.B., which wire

19

transfer request contained R.B.’s name, Florida driver’s license

20

number, address, phone number, and Wells Fargo bank account number.

21

Overt Act No. 27:

On or about April 4, 2016, an unknown

22

coconspirator fraudulently induced R.B. to send a wire transfer of

23

approximately $39,000 from her Wells Fargo account in Panama City

24

Beach, Florida, to the Comerica 2663 Account.

25

Overt Act No. 28:

On or about April 4, 2016, defendant

26

ODIONYENMA sent an email titled “Payment Receipt $39,000,” and a

27

thumbnail photograph, to defendant IRO.

28
23

 1

Overt Act No. 29:

On or about April 7, 2016, an unknown

2

coconspirator fraudulently induced R.B. to send a wire transfer of

3

approximately $30,000 from her Wells Fargo account in Panama City

4

Beach, Florida, to a Wells Fargo account ending in 7410.

5

Overt Act No. 30:

On or about April 12, 2016, defendant

6

ODIONYENMA sent defendant IRO a photograph of the wire transfer

7

request for approximately $30,000 from the Wells Fargo account of

8

R.B.

9

Overt Act No. 31:

On or about April 13, 2016, defendant IRO

10

emailed to defendant AWAK a photograph of the wire transfer request

11

by R.B. for approximately $18,000 and a photograph of wire transfer

12

information for the wire by R.B. of approximately $39,000, and asked

13

defendant AWAK to make a receipt “relating to equipment.”

14

Overt Act No. 32:

On or about April 14, 2016, defendant AWAK

15

emailed to defendant IRO a file containing a purported invoice from

16

“IRVA Auto Sales Equipment Broker LLC” to R.B., which invoice falsely

17

purported to be for two payments in January and February 2019,

18

totaling approximately $39,000.

19
20

Victim F.K.
Overt Act No. 33:

On or about May 30, 2016, an unknown

21

coconspirator fraudulently induced F.K. to send a wire transfer of

22

approximately $6,824 from a bank account in Japan to a Chase account

23

ending in 1577 of UICC 2, in Los Angeles, California (the “Chase 1577

24

Account”).

25

Overt Act No. 34:

On or about July 13, 2016, an unknown

26

coconspirator fraudulently induced F.K. to send a wire transfer of

27

approximately $33,128.26 from a bank account in Japan to a Chase

28
24

 1

account ending in 0655 of UICC 1, in Los Angeles, California (the

2

“Chase 0655 Account”).

3

Overt Act No. 35:

On or about October 12, 2016, an unknown

4

coconspirator fraudulently induced victim F.K. to travel to Los

5

Angeles to assist in releasing the funds that F.K. sent to the Chase

6

0655 Account.

7

Overt Act No. 36:

On or about October 13, 2016, defendant

8

MANSBANGURA took F.K. to a Chase branch in Los Angeles in an attempt

9

to have Chase release the funds that F.K. sent to the Chase 0655

10

Account.

11

Overt Act No. 37:

On or about October 13, 2016, defendant

12

MANSBANGURA sent defendant IGBOKWE a photograph of F.K. in Los

13

Angeles, and told defendant IGBOKWE that she had just dropped off

14

F.K.

15

Overt Act No. 38:

On an unknown date, an unknown coconspirator

16

fraudulently induced victim F.K. to send him a photograph of the wire

17

transfer request of approximately $33,128.26 to the Chase 0655

18

Account, which listed F.K.’s name and address, and UICC 1’s account

19

number, routing number, and address.

20

Overt Act No. 39:

On or about March 24, 2017, defendant

21

ANUNOBI asked defendant IGBOKWE about the funds that F.K. sent

22

through a wire transfer to the Chase 0655 Account, and sent defendant

23

IGBOKWE the photograph of the wire transfer request of approximately

24

$33,128.26 to the Chase 0655 Account, which listed F.K.’s name and

25

address, and UICC 1’s account number, routing number, and address.

26

Overt Act No. 40:

On or about March 27, 2017, defendant

27

IGBOKWE sent to defendant MANSBANGURA the photograph of the wire

28

transfer request of approximately $33,128.26 to the Chase 0655
25

 1

Account, which listed F.K.’s name and address, and UICC 1’s account

2

number, routing number, and address, and requested that defendant

3

MANSBANGURA call Chase to inquire about the funds.

4
5

Victim J.G.
Overt Act No. 41:

On or about October 26, 2016, an unknown

6

coconspirator fraudulently induced victim J.G. to send a wire

7

transfer of approximately $30,000 from a bank account at Heritage

8

Bank of Nevada to a US Bank account ending in 2669 of UICC 1, in Los

9

Angeles, California (the “US Bank 2669 Account”).

10

Overt Act No. 42:

On or about October 27, 2016, defendants

11

IGBOKWE and MANSBANGURA caused a check for approximately $5,500 to be

12

issued from the US Bank 2669 Account to defendant MANSBANGURA.

13

Overt Act No. 43:

On or about October 27, 2016, defendants

14

IGBOKWE and MANSBANGURA caused a check for approximately $7,580 to be

15

issued from the US Bank 2669 Account to UICC 2.

16

Overt Act No. 44:

On or about October 28, 2016, defendants

17

IGBOKWE and MANSBANGURA caused a check for approximately $8,845 to be

18

issued from the US Bank 2669 Account to UICC 2.

19

Overt Act No. 45:

On or about October 31, 2016, defendants

20

IGBOKWE and MANSBANGURA caused a check for approximately $7,500 to be

21

issued from the US Bank 2669 Account to defendant MANSBANGURA.

22
23

Victim Company 3
Overt Act No. 46:

On or about December 19, 2016, an unknown

24

coconspirator fraudulently induced Victim Company 3 to send a wire

25

transfer of approximately $18,457.13 from its Chase account in

26

Oklahoma to a US Bank account ending in 2982 of UICC 2, in Los

27

Angeles, California (“US Bank 2982 Account”).

28
26

 1

Overt Act No. 47:

On or about December 20, 2016, defendants

2

IGBOKWE and MANSBANGURA caused approximately $8,500 to be withdrawn

3

as cash from the US Bank 2982 Account.

4
5

Victim B.Z.
Overt Act No. 48:

On or about February 24, 2017, defendant

6

IGBOKWE sent defendant ONUWA the account information for a Chase

7

account ending in 7605 of UICC 1, in Los Angeles, California (the

8

“Chase 7605 Account”), including the name of UICC 1, the account

9

number, and the routing number.

10

Overt Act No. 49:

On or about March 14, 2017, defendant ONUWA

11

told defendant IGBOKWE that he wanted to use the Chase 7605 Account,

12

which defendant IGBOKWE said was “Ok.”

13

Overt Act No. 50:

On or about March 16, 2017, an unknown

14

coconspirator fraudulently induced victim B.Z. to send a wire

15

transfer of approximately $11,900 from his Chemical Bank account in

16

Michigan to the Chase 7605 Account.

17

Overt Act No. 51:

On or about March 16, 2017, defendant ONUWA

18

sent defendant IGBOKWE a photograph showing an application and

19

agreement for a wire transfer from B.Z.’s Chemical Bank account to

20

the Chase 7605 Account.

21

Overt Act No. 52:

On or about March 22, 2017, defendants

22

IGBOKWE and ONUWA discussed how defendants IGBOKWE and MANSBANGURA

23

would withdraw the funds fraudulently obtained from B.Z.

24

Overt Act No. 53:

On or about March 24, 2017, defendant

25

IGBOKWE told defendant ONUWA that the funds fraudulently obtained

26

from B.Z. were “out,” and defendant ONUWA provided defendant IGBOKWE

27

with his Nigerian bank account number.

28
27

 1

Overt Act No. 54:

On or about March 27, 2017, defendant

2

MANSBANGURA caused a check for approximately $4,000 to be issued from

3

the Chase 7605 Account, with the memo line indicating that the check

4

was for “Rent.”

5

Overt Act No. 55:

On or about April 4, 2017, defendant IGBOKWE

6

provided defendant ONUWA’s name and Nigerian bank account number to

7

UICC 4, with the instruction to pay approximately 3,123,000 naira to

8

the account.

9

Overt Act No. 56:

On or about April 6, 2017, defendant IGBOKWE

10

provided defendant ONUWA’s name and Nigerian bank account number to

11

defendant IRO, with the request that he pay approximately 1,000,000

12

naira to the account.

13

Overt Act No. 57:

On or about April 6, 2017, defendant IRO

14

provided defendant ONUWA’s name and Nigerian bank account number to

15

UICC 3, with the request that he pay approximately 1,000,000 naira to

16

the account.

17
18

Victim Company 4
Overt Act No. 58:

On or about March 27, 2017, defendant

19

UMEJESI sent defendant IGBOKWE the account information for a Wells

20

Fargo account ending in 7245 of UICC 9 (the “Wells Fargo 7245

21

Account”), including the name of UICC 9, the account number, and the

22

routing number.

23

Overt Act No. 59:

On or about March 29, 2017, an unknown

24

coconspirator fraudulently induced Victim Company 4 to send a wire

25

transfer of approximately $29,679.17 from Banco Bilbao Vizcaya

26

Argentaria, S.A., in Colombia, to the Wells Fargo 7245 Account.

27
28
28

 1

Overt Act No. 60:

On or about March 29, 2017, defendant

2

IGBOKWE sent defendant UMEJESI a screenshot of a wire transfer

3

confirmation from Victim Company 4 for $29,679.17.

4

Overt Act No. 61:

On or about March 30, 2017, defendant

5

UMEJESI told defendant IGBOKWE that he was going to the bank, told

6

defendant IGBOKWE the username and password for online access to the

7

Wells Fargo 7245 Account, and sent defendant IGBOKWE the name of UICC

8

9.

9

Overt Act No. 62:

On or about March 31, 2017, defendants

10

IGBOKWE and UMEJESI caused a check of approximately $11,160 to be

11

issued in the name of defendant UMEJESI from the Wells Fargo 7245

12

Account.

13

Overt Act No. 63:

On or about March 31, 2017, defendants

14

IGBOKWE and UMEJESI caused a check of approximately $16,520 to be

15

issued in the name of defendant OJIMBA from the Wells Fargo 7245

16

Account.

17

Overt Act No. 64:

On or about March 31, 2017, defendant

18

UMEJESI sent defendant IGBOKWE a photograph of a deposit slip showing

19

a deposit of approximately $11,160 to a Chase account ending in 7290,

20

in Inglewood, California.

21

Overt Act No. 65:

On or about March 31, 2017, defendant

22

UMEJESI sent defendant IGBOKWE a photograph of a deposit slip showing

23

the deposit of a check issued by UICC 9 to defendant OJIMBA in the

24

amount of approximately $16,520 to a Chase account ending 1767, in

25

Inglewood, California.

26

Overt Act No. 66:

27

On or about April 1, 2017, defendant IGBOKWE

told defendant UMEJESI that they were entitled to 40 percent of the

28
29

 1

amount received from Victim Company 4, which was approximately

2

$11,840.

3
4

Victim Company 5
Overt Act No. 67:

On or about February 17, 2017, defendant IRO

5

told defendant IGBOKWE to have defendant MANSBANGURA take UICC 1 to a

6

bank to open a bank account in the name of Victim Company 5.

7

Overt Act No. 68:

On or about February 17, 2017, defendant

8

IGBOKWE sent defendant MANSBANGURA the message from defendant IRO

9

about taking UICC 1 to a bank to open a bank account in the name of

10
11

Victim Company 5.
Overt Act No. 69:

On or about February 22, 2017, defendant

12

MANSBANGURA caused UICC 1 to open a bank account at Chase ending in

13

5027 in a name similar to that of Victim Company 5 (the “Chase 5027

14

Account”).

15

Overt Act No. 70:

On or about March 20, 2017, defendant

16

IGBOKWE sent to defendant IRO the account information for the Chase

17

5027 Account, including the account number and the routing number.

18

Overt Act No. 71:

On or about April 4, 2017, Wells Fargo

19

received a letter purporting to be from Victim Company 5, which

20

included a notarized letter and forged signature of the Chief

21

Executive Officer of Victim Company 5, requesting the closure of

22

Victim Company 5’s Wells Fargo account and the transfer of the

23

current balance — which at the time was approximately $17,300,844.58

24

— to the Chase 5027 Account.

25

Overt Act No. 72:

On or about June 5, 2017, Wells Fargo

26

received a letter by U.S. Mail purporting to be from Victim Company

27

5, requesting the closure of Victim Company 5’s Wells Fargo account

28
30

 1

and transfer of the current balance — which at the time was

2

approximately $12,760,922.93 — to the Chase 5027 Account.

3
4

Victim A.V.
Overt Act No. 73:

On or about April 10, 2017, defendants

5

IGBOKWE and CHILAKA discussed a payment from A.V. anticipated to

6

arrive in a Wells Fargo account ending in 1147 of UICC 26, in Los

7

Angeles, California (the “Wells Fargo 1147 Account”), including

8

discussion of the name of UICC 26, the account number, and the

9

routing number.

10

Overt Act No. 74:

On or about April 11, 2017, an unknown

11

coconspirator fraudulently induced A.V. to request a wire transfer of

12

approximately $8,035 from her Capital One account in Maryland to the

13

Wells Fargo 1147 Account.

14

Overt Act No. 75:

On or about April 11, 2017, defendant

15

CHILAKA sent defendant IGBOKWE a copy of a wire transfer request

16

submitted by A.V. on April 11, 2017, requesting transfer of

17

approximately $8,035 from her Capital One account in Maryland to the

18

Wells Fargo 1147 Account.

19

Overt Act No. 76:

On or about April 17, 2017, after defendant

20

IGBOKWE sent defendant CHILAKA the account information for a BOA

21

account ending in 3037 of UICC 26, defendant CHILAKA asked for a bank

22

account that did not use a Nigerian name.

23

Overt Act No. 77:

On or about April 17, 2017, defendant

24

IGBOKWE sent defendant CHILAKA the account information for the Chase

25

5027 Account, including the name of UICC 1, the account number, and

26

the routing number.

27
28

Overt Act No. 78:

On or about April 27, 2017, an unknown

coconspirator fraudulently induced A.V. to send a wire transfer of
31

 1

approximately $2,700 from her Capital One account in Maryland to the

2

Chase 5027 Account.

3

Overt Act No. 79:

On or about April 27, 2017, defendant

4

MANSBANGURA sent defendant IGBOKWE photographs of a Chase banking

5

application on a phone showing that an approximately $2,700 wire

6

transfer from A.V. was pending in the Chase 5027 Account.

7

Overt Act No. 80:

On or about April 27, 2017, defendant

8

IGBOKWE sent defendant CHILAKA photographs of a Chase banking

9

application on a phone showing that an approximately $2,700 wire

10
11

transfer from A.V. was pending in the Chase 5027 Account.
Overt Act No. 81:

On or about May 1, 2017, an unknown

12

coconspirator fraudulently induced A.V. to send a wire transfer of

13

approximately $3,360 from her Capital One account in Maryland to the

14

Chase 5027 Account.

15

Overt Act No. 82:

On or about May 1, 2017, defendant

16

MANSBANGURA sent defendant IGBOKWE a photograph of a Chase banking

17

application on a phone showing that an approximately $3,360 wire

18

transfer from A.V. was pending in the Chase 5027 Account.

19

Overt Act No. 83:

On or about April 27, 2017, defendant

20

IGBOKWE sent defendant CHILAKA photographs of a Chase banking

21

application on a phone showing that an approximately $3,360 wire from

22

A.V. was pending in the Chase 5027 Account.

23

Overt Act No. 84:

On or about May 8, 2017, defendant

24

MANSBANGURA told defendant IGBOKWE not use the Chase 5027 Account to

25

receive transactions from Capital One because Chase was scrutinizing

26

transactions from Capital One for fraud.

27
28

Overt Act No. 85:

On or about June 2, 2017, defendant CHILAKA

sent defendant IGBOKWE a voicemail from A.V. for a purported “Mr.
32

 1

Davis,” in which A.V. discussed having spoken to her Chase banker

2

about the release of the $3,360 wire.

3

Overt Act No. 86:

On or about June 2, 2017, defendant IGBOKWE

4

sent defendant CHILAKA an audio recording of defendant MANSBANGURA

5

calling Chase while posing as UICC 1, and asking about the status of

6

the $3,360 wire.

7
8
9

Victims Je.F. and Jo.F.
Overt Act No. 87:

On or about April 17, 2017, an unknown

coconspirator fraudulently induced Je.F. to send a wire transfer of

10

approximately $135,800 from the BMO Harris Bank account of Je.F. and

11

Jo.F. in Illinois to a Chase account ending in 6217 of UICC 24, in

12

Hawthorne, California (“Chase 6217 Account”).

13

Overt Act No. 88:

On or about April 18, 2017, defendant IRO

14

sent defendant EKECHUKWU the account information for the Chase 6217

15

Account, including the account number and the routing number, and

16

told him “Check this. Something is inside[.]”

17

Overt Act No. 89:

On or about April 19 and 20, 2017, defendant

18

IRO discussed with defendant ANOZIE information from defendant

19

AZUBUIKE related to defrauding Je.F. and Jo.F.

20

Overt Act No. 90:

On or about April 19, 2017, defendant IRO

21

complained to defendant EKECHUKWU that, after a call by Chase to UICC

22

24, UICC 24 stated that he wanted to send the $135,800 back.

23
24

Victim Company 6
Overt Act No. 91:

On or about April 10, 2017, defendant NNAMDI

25

asked defendant IRO to open a bank account in the name of a specific

26

Chinese company (“Chinese Company 1”) with which Victim Company 6 had

27

a business relationship.

28
33

 1

Overt Act No. 92:

On or about April 10, 2017, defendant IRO

2

asked defendant CATHEY to open a bank account in the name of Chinese

3

Company 1.

4

Overt Act No. 93:

On or about April 12, 2017, defendant CATHEY

5

sent defendant IRO the account information for a PNC Bank account

6

ending in 7988, opened by UICC 10 in the name of Chinese Company 1,

7

in Atlanta, Georgia (the “PNC Bank 7988 Account”).

8
9

Overt Act No. 94:

On or about April 17, 2017, after defendant

NNAMDI told defendant IRO that he had emailed defendant IRO a copy of

10

the “invoice” sent to Victim Company 6, defendant IRO told defendant

11

CATHEY that Victim Company 6 was expected to pay $900,000 to the PNC

12

Bank 7988 Account.

13

Overt Act No. 95:

On or about April 18, 2017, an unknown

14

coconspirator fraudulently induced Victim Company 6 to send a wire

15

transfer of approximately $900,000 from its Commerce State Bank

16

account in Wisconsin to the PNC Bank 7988 Account.

17

Overt Act No. 96:

On or about April 18, 2017, defendant IRO

18

sent defendant CATHEY a screenshot of a wire confirmation page

19

containing details for the $900,000 wire ordered by Victim Company 6

20

to the PNC Bank 7988 Account, and wrote, “Done [¶] Hahahaha.”

21

Overt Act No. 97:

On or about April 19, 2017, defendant CATHEY

22

told defendant IRO how defendant CATHEY had flown to Atlanta to

23

oversee withdrawal of the funds fraudulently obtained from Victim

24

Company 6.

25

Overt Act No. 98:

On or about April 24, 2017, defendant CATHEY

26

sent defendant IRO account information for a Chase account ending in

27

5899, opened in the name of Chinese Company 1 in Los Angeles,

28
34

 1

California (“Chase 5899 Account”), which defendant IRO said he would

2

keep for use later.

3
4

Victim Company 7
Overt Act No. 99:

On or about April 21, 2017, an unknown

5

coconspirator fraudulently induced Victim Company 7 to send a wire

6

transfer of approximately $23,789, intended for Victim Company 8,

7

from Victim Company 7’s BOA account in North Carolina to the Chase

8

checking account ending in 7866 of UICC 25, in Carson, California

9

(the “Chase 7866 Account”).

10

Overt Act No. 100:

On or about April 21, 2017, defendant IRO

11

caused approximately $2,700 to be transferred from the Chase 7866

12

Account to the Chase savings account ending in 9927 of UICC 25, in

13

Carson, California (the “Chase 9927 Account”).

14

Overt Act No. 101:

On or about April 24, 2017, defendant IRO

15

caused a wire transfer of approximately $18,598 to be sent from the

16

Chase 7866 Account to a SunTrust account of “B&B Motors of Tampa Bay

17

Inc.,” with the wire notes saying “This payment is for car purchase

18

of Mr. Brown's; Payment For Mr Brown's Car Buy.”

19

Overt Act No. 102:

On or about April 24, 2017, defendant IRO

20

caused approximately $500 to be withdrawn from the Chase 7866 Account

21

as cash through an ATM.

22

Overt Act No. 103:

On or about April 25, 2017, defendant IRO

23

caused a wire transfer of approximately $1450 to be sent from the

24

Chase 7866 Account to a U.S. Bank account ending in 0953.

25

Overt Act No. 104:

On or about April 26, 2017, defendant IRO

26

sent defendant ANOZIE photographs of a phone showing a Chase banking

27

application containing information related to the wire of

28

approximately $23,789 from Victim Company 7.
35

 1
2

Victim D.J.
Overt Act No. 105:

On or about January 20, 2017, defendants

3

IGBOKWE and MANSBANGURA assisted defendant P. DURU in filing an

4

application for a Fictitious Business Name Statement with the Los

5

Angeles County Registrar-Recorder/County Clerk’s Office in the name

6

“PD Enterprise.”

7

Overt Act No. 106:

On or about March 14, 2017, defendant

8

P. DURU sent defendant IGBOKWE account information for a Wells Fargo

9

account ending in 4859 of defendant P. DURU, dba “PD Enterprise,” in

10
11

Sacramento, California (the “BOA 4859 Account”).
Overt Act No. 107:

On or about April 7, 2017, in response to

12

defendant IGBOKWE’s request that defendant P. DURU open a bank

13

account at Wells Fargo, defendant P. DURU sent defendant IGBOKWE

14

account information for a Wells Fargo account ending in 4899 of

15

defendant P. DURU, dba “PD Enterprise,” in San Francisco, California

16

(the “Wells Fargo 4899 Account”).

17

Overt Act No. 108:

On or about April 24, 2017, defendant

18

IGBOKWE sent defendant ODIONYENMA the account information for the

19

Wells Fargo 4899 Account, including the account number and the

20

routing number.

21

Overt Act No. 109:

On or about May 3, 2017, defendant

22

ODIONYENMA asked defendant IGBOKWE to confirm that he could use the

23

Wells Fargo 4899 Account to receive a romance scam payment of

24

approximately $25,000.

25

Overt Act No. 110:

On or about May 5, 2017, an unknown

26

coconspirator fraudulently induced D.J. to purchase a money order of

27

approximately $25,600 from United Southwest Bank in Minnesota and

28

deposit it into the Wells Fargo 4899 Account.
36

 1

Overt Act No. 111:

On or about May 5, 2017, defendant

2

ODIONYENMA sent defendant IGBOKWE a photograph of a check deposit

3

receipt showing that approximately $25,600 had been deposited into

4

the Wells Fargo 4899 Account.

5

Overt Act No. 112:

On or about May 5 and 6, 2017, defendants

6

ODIONYENMA and IGBOKWE discussed the exchange rate that defendant

7

IGBOKWE would provide, with defendant ODIONYENMA ultimately providing

8

a Nigerian bank account where defendant IGBOKWE was to deposit

9

7,272,000 naira.

10

Overt Act No. 113:

On or about May 11, 2017, defendant P. DURU

11

complained to defendant IGBOKWE that receiving 10 percent of the

12

fraudulently-obtained funds — rather than his usual 20 percent for

13

romance scam laundering or 40 percent for BEC fraud laundering — was

14

insufficient given the “risk” involved, and defendant IGBOKWE

15

responded, “Lol.”

16
17

Victim L.B.
Overt Act No. 114:

On or about May 1, 2017, defendant IGBOKWE

18

sent defendant IRO the account information, including the account

19

number and the routing number, for a BOA account ending in 2660, in

20

Los Angeles, California (the “BOA 2660 Account”) opened in defendant

21

IGBOKWE’s name.

22

Overt Act No. 115:

On or about May 3, 2017, defendant IRO

23

provided defendant AWAK with defendant IGBOKWE’s BOA 2660 Account to

24

receive an approximately $3,000 romance scam payment.

25

Overt Act No. 116:

On or about May 4, 2017, defendant AWAK sent

26

defendant IRO a photograph of a wire transfer request from L.B.’s

27

Wells Fargo account in Alabama to the BOA 2660 Account, but the wire

28

transfer request spelled defendant IGBOKWE’s name incorrectly.
37

 1

Overt Act No. 117:

On or about May 9, 2017, after defendant IRO

2

sent defendant AWAK the correct account-holder name on the BOA 2660

3

Account, defendant AWAK told defendant IRO that L.B. was at the bank

4

re-sending a wire transfer.

5

Overt Act No. 118:

On or about May 9, 2017, an unknown

6

coconspirator fraudulently induced L.B. to send a wire transfer of

7

approximately $3,000 from her Wells Fargo account to the BOA 2660

8

Account.

9

Overt Act No. 119:

On or about May 15, 2017, defendant IRO

10

instructed UICC 3 to pay 742,500 naira from his Nigerian bank account

11

to defendant AWAK’s Nigerian bank account.

12

Overt Act No. 120:

On or about June 7, 2017, defendant IGBOKWE

13

used approximately $1,225 from the BOA 2660 Account to pay the U.S.

14

Customs and Immigration Service in connection with his application

15

for lawful permanent residence.

16
17

Victim Company 9
Overt Act No. 121:

On or about April 24, 2017, defendant

18

IGBOKWE sent defendant UZOKA the account information for a BOA

19

account ending in 1004 of UICC 11, in Northridge, California (the

20

“BOA 1004 Account”), including the name of UICC 11, the account

21

number, and the routing number.

22

Overt Act No. 122:

On or about April 28, 2017, in response to

23

defendant UZOKA’s inquiry about whether the BOA 1004 Account was

24

“still good,” defendant IGBOKWE responded with a “thumbs up”

25

pictograph.

26

Overt Act No. 123:

On or about May 3, 2017, defendant UZOKA

27

sent defendant IGBOKWE an email that had been sent by an employee of

28

Victim Company 9 to a hacked email account of a Caribbean company
38

 1

with which Victim Company 9 was doing business, and defendant UZOKA

2

also told defendant IGBOKWE that the fraudulent transaction would be

3

approximately $220,000.

4

Overt Act No. 124:

On or about May 10, 2017, an unknown

5

coconspirator fraudulently induced Victim Company 9 to send a wire

6

transfer of approximately $220,462.68 from its account at First

7

Caribbean International Bank to the BOA 1004 Account.

8
9

Overt Act No. 125:

On or about May 10, 2017, defendant UMEJESI

sent defendant IGBOKWE a screenshot of a banking application

10

indicating that the fraudulent wire from Victim Company 9 had been

11

deposited into the BOA 1004 Account, which defendant IGBOKWE then

12

sent to defendant UZOKA.

13

Overt Act No. 126:

On or about May 11, 2017, defendant IKOGHO

14

sent defendant IRO the account information for a BOA account ending

15

in 5283 (the “BOA 5283 Account”), including the account number and

16

the routing number.

17

Overt Act No. 127:

On or about May 11, 2017, defendant OGUNGBE

18

sent defendant IRO the account information for a BOA account ending

19

in 9405 (the “BOA 9405 Account”), including the account number and

20

the routing number.

21

Overt Act No. 128:

On or about May 11, 2017, defendant IGBOKWE

22

sent defendant UMEJESI the account information for the BOA 5283

23

Account and the BOA 9405 Account, including the account numbers and

24

the routing numbers, which information defendant IGBOKWE had received

25

from defendant IRO.

26

Overt Act No. 129:

On or about May 11, 2017, defendant UMEJESI

27

caused a transfer of approximately $60,000 to be made from the BOA

28

1004 Account to the BOA 5283 Account, and sent defendant IGBOKWE a
39

 1

photograph of a deposit slip reflecting the transfer, which defendant

2

IGBOKWE, in turn, sent to defendant IRO.

3

Overt Act No. 130:

On or about May 12, 2017, defendant UMEJESI

4

caused a transfer of approximately $75,500 to be made from the BOA

5

1004 Account to the BOA 9405 Account, and sent defendant IGBOKWE a

6

photograph of a deposit slip reflecting the transfer, which defendant

7

IGBOKWE, in turn, sent to defendant IRO.

8
9

Overt Act No. 131:

On or about May 13, 2017, defendant IGBOKWE

asked defendant IRO to make payments of approximately 21,300,000

10

naira and approximately 26,802,500 naira to the Nigerian bank account

11

of UICC 5.

12

Overt Act No. 132:

On or about May 13, 2017, defendant IRO

13

asked defendant IKOGHO to pay approximately 21,300,000 naira from his

14

Nigerian bank account to the Nigerian bank account of UICC 5.

15

Overt Act No. 133:

On or about May 15, 2017, defendant UMEJESI

16

caused a cashier’s check of approximately $21,000, addressed to

17

defendant UMEJESI, to be purchased from the BOA 1004 Account.

18

Overt Act No. 134:

On or about May 15, 2017, defendant UMEJESI

19

caused a cashier’s check of approximately $9,500, addressed to

20

defendant IGBOKWE, to be purchased from the BOA 1004 Account.

21

Overt Act No. 135:

On or about May 15, 2015, defendant UMEJESI

22

caused a transfer of approximately $30,000 to be made from the BOA

23

1004 Account to the BOA 9405 Account.

24

Overt Act No. 136:

On or about May 15, 2017, defendant IGBOKWE

25

asked UICC 5 to transfer approximately 7,750,000 naira from her

26

Nigerian bank account to the Nigerian bank account of defendant

27

UZOKA.

28
40

 1

Overt Act No. 137:

On or about May 16, 2017, after defendant

2

OGUNGBE told defendant IRO that he was unable to transfer

3

approximately 26,802,500 naira to the Nigerian bank account of UICC 4

4

as defendant IRO had requested, defendant IRO requested that

5

defendant OGUNGBE transfer the money to the Nigerian bank account of

6

UICC 3.

7

Overt Act No. 138:

On or about May 17, 2017, defendant IRO

8

asked UICC 3 to pay approximately 17,500,000 naira to the Nigerian

9

bank account of defendant UZOKA and approximately 9,152,500 naira to

10
11

the Nigerian bank account of UICC 5.
Overt Act No. 139:

On or about May 19, 2017, defendant IGBOKWE

12

asked UICC 5 to transfer approximately 8,000,000 naira from her

13

Nigerian bank account to the Nigerian bank account of defendant

14

UZOKA.

15

Overt Act No. 140:

On or about May 23, 2017, defendant IGBOKWE

16

asked UICC 5 to transfer approximately 3,150,000 naira from her

17

Nigerian bank account to the Nigerian bank account of defendant

18

UZOKA.

19
20

Victim Law Firm
Overt Act No. 141:

On or about May 4, 2017, defendant IGBOKWE

21

asked defendant IRO whether he could use the Chase 5899 Account,

22

which account information defendant IRO had sent him earlier, to

23

receive a BEC fraud payment.

24

Overt Act No. 142:

On or about May 2, 2017, after defendant

25

IGBOKWE sent him the Chase 5899 Account and a U.S. Bank account

26

ending in 0362 of UICC 9 (the “US Bank 0362 Account”), defendant

27

OCHIAGHA confirmed that he would use both accounts to receive BEC

28

fraud payments totaling more than $400,000.
41

 1

Overt Act No. 143:

On or about May 11, 2017, an unknown

2

coconspirator fraudulently induced the Victim Law Firm to send a wire

3

transfer of approximately $83,140.98 from its account at SunTrust in

4

North Carolina to the Chase 5899 Account.

5

Overt Act No. 144:

On or about May 11, 2017, defendant OCHIAGHA

6

told defendant IGBOKWE that a fraudulent payment would arrive in the

7

Chase 5899 Account.

8
9

Overt Act No. 145:

On or about May 11, 2017, after defendant

IRO told defendant CATHEY that a fraudulent payment would arrive in

10

the Chase 5899 Account, defendant CATHEY reported to defendant IRO

11

that $83,000 had arrived.

12

Overt Act No. 146:

On or about May 11, 2017, defendant IRO

13

reported to defendant IGBOKWE that $83,000 had arrived in the Chase

14

5899 Account.

15

Overt Act No. 147:

On or about May 12 and 13, 2017, defendants

16

IRO and CATHEY expressed concern to each other that the wire of

17

approximately $83,140.98 that had arrived was from a U.S. law firm,

18

and discussed requesting that Chase return the funds in order to

19

avoid further scrutiny for the transaction.

20
21

Victim D.V.
Overt Act No. 148:

On or about May 13, 2017, an unknown

22

coconspirator fraudulently induced D.V. to send approximately $500 by

23

Western Union to the account of UICC 1, in Los Angeles, California.

24

Overt Act No. 149:

On or about May 14, 2017, defendant IGBOKWE

25

sent defendant MANSBANGURA the information needed to receive the

26

funds that D.V. sent by Western Union on May 13, 2015, including

27

D.V.’s name, D.V.’s address, a unique tracking number needed to

28

receive the money, and UICC 1’s name.
42

 1

Overt Act No. 150:

On or about May 15, 2017, an unknown

2

coconspirator fraudulently induced D.V. to send approximately $500 by

3

Western Union to the account of UICC 1, in Los Angeles, California.

4

Overt Act No. 151:

On or about May 15, 2017, defendant IGBOKWE

5

sent defendant MANSBANGURA the information needed to receive the

6

funds that D.V. sent by Western Union on May 15, 2015, including

7

D.V.’s name, and D.V.’s address, and told defendant MANSBANGURA that

8

the funds had been sent to UICC 1’s account.

9

Overt Act No. 152:

On or about May 15, 2017, defendant

10

MANSBANGURA caused $500 sent by D.V. to UICC 1 through Western Union

11

to be withdrawn in Los Angeles, California.

12

Overt Act No. 153:

On or about May 15, 2017, defendant

13

MANSBANGURA caused $500 sent by D.V. to UICC 1 through Western Union

14

to be withdrawn in Los Angeles, California.

15

Victim Company 10

16

Overt Act No. 154:

On or about May 11, 2017, defendant OCHIAGHA

17

requested that defendant IGBOKWE open a bank account in the name of a

18

U.S. company based in Pennsylvania (the “Pennsylvania Company”) at a

19

bank other than First National Bank, where defendant OCHIAGHA said

20

the Pennsylvania Company held its legitimate bank account.

21

Overt Act No. 155:

On or about May 12, 2017, after defendant

22

IGBOKWE asked defendant IRO to open a bank account in the name of the

23

Pennsylvania Company, defendant IRO asked defendant CATHEY to open a

24

bank account in the name of the Pennsylvania Company.

25

Overt Act No. 156:

On or about May 15, 2017, defendant CATHEY

26

provided account information to defendant IRO for a Chase account

27

ending in 7262, opened in the name of the Pennsylvania Company by

28
43

 1

UICC 12, in Inglewood, California (“Chase 7262 Account”), including

2

the account number and the routing number.

3

Overt Act No. 157:

On or about May 15, 2017, defendant IRO

4

provided account information to defendant IGBOKWE for the Chase 7262

5

Account, including the account number and the routing number, who

6

then provided the account information to defendant OCHIAGHA.

7

Overt Act No. 158:

On or about May 17, 2017, an unknown

8

coconspirator fraudulently induced Victim Company 10 to send a wire

9

transfer of approximately $301,201.20 from its account at China

10
11

Merchants Bank in China to the Chase 7262 Account.
Overt Act No. 159:

On or about May 17, 2017, defendant IGBOKWE

12

sent defendant IRO a screenshot showing a wire confirmation page for

13

the wire from Victim Company 10 to the Chase 7262 Account.

14

Overt Act No. 160:

On or about May 17, 2017, defendant IRO

15

instructed defendant CATHEY to begin to “service” the Chase 7262

16

Account, in anticipation of withdrawing the fraudulently-obtained

17

funds.

18

Overt Act No. 161:

On or about May 19, 2017, defendants IRO and

19

CATHEY discussed that Victim Company 10 had found out about the BEC

20

fraud scheme.

21
22

Victim T.P.
Overt Act No. 162:

On or about May 2, 2017, after defendant IRO

23

asked defendant CATHEY to open a bank account in the name of a

24

specific Chinese company (“Chinese Company 4”), defendant CATHEY sent

25

defendant IRO the account information for a Chase account ending in

26

7522, in Los Angeles, California (the “Chase 7522 Account”),

27

including the account number and routing number, and defendant IRO

28

sent that information to defendant NNAMDI.
44

 1

Overt Act No. 163:

On or about June 5, 2017, defendant NNAMDI

2

sent defendant IRO an email from T.P., which indicated that T.P. had

3

been fraudulently induced to make a payment.

4

Overt Act No. 164:

On or about June 5, 2017, an unknown

5

coconspirator fraudulently-induced T.P. to send a wire transfer of

6

approximately $64,554 from an HSBC account in Hong Kong to the Chase

7

7522 Account.

8

Overt Act No. 165:

On or about June 5, 2017, defendant IRO told

9

defendant NNAMDI that the exchange rate that defendant IRO could

10

provide was 60 to 100 naira below market rates because his money

11

exchangers had to “clean” the funds which carried “risk.”

12

Overt Act No. 166:

On or about June 6, 2017, defendants IRO and

13

CATHEY caused approximately $8,500 to be withdrawn as cash from the

14

Chase 7522 Account.

15

Overt Act No. 167:

On or about June 7, 2017, defendants IRO and

16

CATHEY caused approximately $7,100 to be withdrawn as cash from the

17

Chase 7522 Account.

18

Overt Act No. 168:

On or about June 7, 2017, defendants IRO and

19

CATHEY caused an approximately $47,000 wire transfer to be sent from

20

the Chase 7522 Account to the Citibank account of a company in Hong

21

Kong.

22

Overt Act No. 169:

On or about June 7, 2017, defendant NNAMDI

23

sent defendant IRO account information for a Nigerian bank account to

24

which defendant IRO was to have his “exchanger” provide payment.

25

Overt Act No. 170:

On or about June 9, 2017, defendant IRO sent

26

defendant OGUNGBE the Nigerian bank account information that

27

defendant NNAMDI had provided to him, with the instruction to

28

“[t]ransfer 7,965,000” naira and “[c]ount it as 27k usd.”
45

 1

Overt Act No. 171:

On or about June 10, 2017, defendant OGUNGBE

2

confirmed that he had paid 7,965,000 naira to the Nigerian bank

3

account that defendant NNAMDI had provided to defendant IRO.

4
5

Victim Company 11
Overt Act No. 172:

On or about May 25, 2017, defendant XPLORA G

6

asked defendant IRO to open a bank account in the name of a U.S.

7

company (“U.S. Company 1”) in anticipation of an approximately

8

$300,000 BEC fraud payment.

9

Overt Act No. 173:

On or about May 26, 2017, after defendant

10

IRO asked defendant CATHEY to open a bank account in the name of U.S.

11

Company 1, defendant CATHEY caused UICC 12 to file a Fictitious

12

Business Name Statement in the name of U.S. Company 1 with the Los

13

Angeles County Registrar-Recorder/County Clerk’s Office.

14

Overt Act No. 174:

On or about May 26, 2017, after defendant

15

IRO asked defendant CATHEY to open a bank account in the name of U.S.

16

Company 1, defendant CATHEY sent defendant IRO the account

17

information for a BOA account ending in 4180, opened by UICC 12 in

18

the name of U.S. Company 1, in Inglewood, California (the “BOA 4180

19

Account”), including the account number and the routing number.

20

Overt Act No. 175:

On or about May 26, 2017, defendant IRO sent

21

defendant XPLORA G the account information for the BOA 4180 Account,

22

including the account number and the routing number.

23

Overt Act No. 176:

On or about June 13, 2017, an unknown

24

coconspirator fraudulently induced Victim Company 11 to send a wire

25

transfer of approximately $297,617.11 from its account at Arab Bank

26

PLC in Lebanon to the BOA 4180 Account.

27
28
46

 1

Overt Act No. 177:

On or about June 13, 2017, defendant

2

XPLORA G told defendant IRO that Victim Company 11 had paid $297,000

3

into the BOA 4180 Account.

4

Overt Act No. 178:

On or about June 13, 2017, after defendant

5

CATHEY told defendant IRO that BOA had closed the BOA 4180 Account,

6

defendant IRO asked defendant CATHEY to reopen the account.

7

Overt Act No. 179:

On or about June 14, 2017, defendant IRO

8

asked defendant UMEJESI to open a bank account at Chase or Wells

9

Fargo, but not BOA, in the name of U.S. Company 1.

10

Overt Act No. 180:

On or about June 15, 2017, defendant UMEJESI

11

caused UICC 13 to file a Fictitious Business Name Statement in the

12

name of U.S. Company 1 with the Los Angeles County Registrar-

13

Recorder/County Clerk’s Office.

14

Overt Act No. 181:

On or about June 15, 2017, defendant UMEJESI

15

sent defendant IRO the account information for a Wells Fargo account

16

ending in 7984, opened by UICC 13, in Inglewood, California (the

17

“Wells Fargo 7984 Account”), including the account number and the

18

routing number.

19

Overt Act No. 182:

On or about June 16, 2017, an unknown

20

coconspirator fraudulently induced Victim Company 11 to send a wire

21

transfer of approximately $297,617.11 from its account at Arab Bank

22

PLC in Lebanon to the Wells Fargo 7984 Account.

23

Overt Act No. 183:

On or about June 22, 2017, after defendant

24

IRO asked defendant MADEKWE if he was able to launder the funds

25

fraudulently obtained from Victim Company 11 and they discussed the

26

exchange rate that defendant MADEKWE would provide, defendant MADEKWE

27

reported that he was unable to launder the funds because his Wells

28

Fargo account had been closed.
47

 1

Overt Act No. 184:

On or about June 23, 2017, with defendant

2

MADEKWE unable to launder the funds, defendant IRO told defendant

3

UMEJESI to transfer $84,755 from the Wells Fargo 7984 Account to the

4

Wells Fargo account ending in 8463 of R.L., which account

5

information, including R.L.’s name and the account number, had been

6

provided to defendant IRO by defendant IKOGHO.

7

Overt Act No. 185:

On or about June 25, 2017, defendant IRO

8

caused defendant EROHA to file a Fictitious Business Name Statement

9

with the Los Angeles County Registrar-Recorder/County Clerk’s Office,

10
11

in a name similar to that of U.S. Company 1.
Overt Act No. 186:

On or about June 25, 2017, defendant IRO

12

sent XPLORA G the account information for a BOA account ending in

13

3563 opened by defendant EROHA with a business name similar to that

14

of U.S. Company 1, in Inglewood, California (the “BOA 3563 Account”).

15

Victim B.P.

16

Overt Act No. 187:

On or about June 23, 2017, defendant AGUNWA

17

told defendant IGBOKWE that a coconspirator would use the Chase 7605

18

Account to receive an approximately $750 fraud payment.

19

Overt Act No. 188:

On or about June 23, 2017, an unknown

20

coconspirator fraudulently induced B.P. to send a wire transfer of

21

approximately $750 from her First Hawaiian Bank account in Hawaii to

22

the Chase 7605 Account.

23

Overt Act No. 189:

On or about June 27, 2017, defendant IGBOKWE

24

instructed UICC 4 to make payments of 26,000 naira to defendant

25

AGUNWA’s Nigerian bank account and 183,000 naira to the Nigerian bank

26

account of AGUNWA’s coconspirator.

27
28

Overt Act No. 190:

On or about June 27, 2017, an unknown

coconspirator fraudulently induced B.P. to send a wire transfer of
48

 1

approximately $1,500 from her First Hawaiian Bank account in Hawaii

2

to the Chase 7605 Account.

3

Overt Act No. 191:

On or about June 29, 2017, defendant

4

MANSBANGURA checked the Chase 7605 Account for a payment from B.P.,

5

at the request of defendant IGBOKWE.

6

Overt Act No. 192:

On or about July 5, 2017, defendant IGBOKWE

7

instructed UICC 4 to make payments of 50,000 naira to defendant

8

AGUNWA’s Nigerian bank account and 367,000 naira to the Nigerian bank

9

account of AGUNWA’s coconspirator.

10

Overt Act No. 193:

On or about July 13, 2017, an unknown

11

coconspirator fraudulently induced B.P. to send a wire transfer of

12

approximately $2,550 from her First Hawaiian Bank account in Hawaii

13

to the Chase 7605 Account.

14
15

Victim Solicitor Firm
Overt Act No. 194:

On or about June 20, 2017, defendant

16

OCHIAGHA asked defendant IGBOKWE for a bank account that could be

17

used to receive an approximately $200,000 BEC fraud payment from the

18

Victim Solicitor Firm.

19

Overt Act No. 195:

On or about June 21, 2017, in response to

20

defendant IGBOKWE’s request to open a bank account that could receive

21

an approximately $200,000 BEC fraud payment, defendant IRO sent

22

defendant IGBOKWE the account information for a Chase account ending

23

in 7633 of UICC 14, in Culver City, California (“Chase 7633

24

Account”), including the account number and the routing number.

25

Overt Act No. 196:

On or about June 22, 2017, an unknown

26

coconspirator fraudulently induced the Victim Solicitor Firm to send

27

a wire transfer of approximately $199,960 from its account at Lloyds

28

Bank in the United Kingdom to the Chase 7633 Account.
49

 1

Overt Act No. 197:

On June 22, 2017, after defendant CATHEY

2

told defendant IRO that a payment of approximately $199,000 arrived

3

in the Chase 7633 Account and asked about the cut he would receive,

4

defendant IRO told him “[y]ou guys get 40k” and instructed him to

5

“keep the acc[ount] good” by servicing it.

6

Overt Act No. 198:

On or about June 23, 2017, defendants IRO

7

and CATHEY caused a sum of approximately $43,750 to be transferred

8

from the Chase 7633 Account to a Chase account ending in 6781 of UICC

9

15 in Los Angeles, California (“Chase 6781 Account”), which was

10
11

provided to defendant IRO by defendant IKOGHO.
Overt Act No. 199:

On or about June 24, 2017, defendants IRO

12

and CATHEY caused the purchase of a cashier’s check of approximately

13

$9,150 from the Chase 7633 Account.

14
15

Victim Company 12
Overt Act No. 200:

On or about May 25, 2017, following a

16

request by defendant XPLORA G for a bank account in the name of a

17

specific South Korean company (the “Korean Company”), defendant IRO

18

asked defendant CATHEY to open a bank account in the name of the

19

Korean Company.

20

Overt Act No. 201:

On or about May 30, 2017, defendant CATHEY

21

sent defendant IRO the account information for a Chase account ending

22

in 6679 that had been opened in the name of the Korean Company, in

23

Inglewood, California (“Chase 6679 Account”), including the account

24

number and the routing number, which information defendant IRO

25

provided to defendant XPLORA G.

26
27

Overt Act No. 202:

On or about June 28, 2017, an unknown

coconspirator attempted to fraudulently induce Victim Company 12 to

28
50

 1

send a wire transfer of approximately $2,502,585.30 from its account

2

in Texas to the Chase 6679 Account.

3

Overt Act No. 203:

On or about June 30, 2017, defendant

4

XPLORA G told defendant IRO that the payment would be from Victim

5

Company 12 to the Korean Company, and defendant IRO provided that

6

information to defendant CATHEY.

7
8

Victim D.A.
Overt Act No. 204:

On or about June 16, 2017, an unknown

9

coconspirator fraudulently induced D.A. to send a wire transfer of

10

approximately $500 from his Capital City Bank account in Kansas to

11

the Chase 5027 Account.

12

Overt Act No. 205:

On or about June 16, 2017, defendant NWANGWU

13

sent defendant IGBOKWE a wire transfer confirmation page for an

14

approximately $500 wire from D.A. to the Chase 5027 Account, which

15

listed D.A.’s name, address, and social security number.

16

Overt Act No. 206:

On or about June 16, 2017, defendant IGBOKWE

17

sent to defendant MANSBANGURA the wire confirmation page for the

18

approximately $500 wire from D.A. to the Chase 5027 Account, which

19

listed D.A.’s name, address, and social security number.

20
21

Victim M.G.
Overt Act No. 207:

On or about July 3, 2017, in response to

22

defendant MACWILLIAM CHUKWUOCHA’s request for a bank account that

23

could receive an approximately $11,000 romance scam payment from

24

Mexico, defendant IGBOKWE provided defendant MACWILLIAM CHUKWUOCHA

25

with the account information for the BOA 3563 Account, including the

26

account number and the routing number.

27
28

Overt Act No. 208:

On or about July 6, 2017, an unknown

coconspirator fraudulently induced M.G. to send a wire transfer of
51

 1

approximately $11,000 from her HSBC account in Mexico to defendant

2

EROHA’s BOA 3563 Account.

3

Overt Act No. 209:

On or about July 6, 2017, defendant

4

MACWILLIAM CHUKWUOCHA told defendant IGBOKWE that the “client” had

5

paid approximately $11,000, and sent a photograph of a computer

6

screen showing a wire-transfer order.

7

Overt Act No. 210:

On or about July 10, 2017, defendant IGBOKWE

8

caused defendant EROHA to send a wire transfer of approximately

9

$6,000 from the BOA 3563 Account to a Wells Fargo account ending in

10

5736 of defendant MACWILLIAM CHUKWUOCHA, in Orlando, Florida (the

11

“Wells Fargo 5736 Account”).

12

Overt Act No. 211:

On or about July 11, 2017, defendant IGBOKWE

13

caused to be sent a wire transfer of approximately $2,800 from

14

defendant EROHA’s BOA 3563 Account to the Wells Fargo 5736 Account.

15

Overt Act No. 212:

On or about July 17, 2017, an unknown

16

coconspirator fraudulently induced M.G. to send a wire transfer of

17

approximately $5,000 from her HSBC account in Mexico to defendant

18

EROHA’s BOA 3563 Account.

19

Overt Act No. 213:

On or about July 17, 2017, defendants

20

IGBOKWE and EROHA caused approximately $5,000 to be withdrawn as cash

21

from the BOA 3563 Account and approximately $4,150 to be redeposited

22

into the Wells Fargo 5736 Account.

23

Overt Act No. 214:

On or about December 15, 2017, an unknown

24

coconspirator fraudulently induced M.G. to send a wire transfer of

25

approximately $5,500 from her HSBC account in Mexico to a BOA account

26

ending in 3349 of defendant AJAEZE in Harbor City, California (the

27

“BOA 3349 Account”).

28
52

 1

Overt Act No. 215:

On or about December 22, 2017, an unknown

2

coconspirator fraudulently induced M.G. to send a wire transfer of

3

approximately $2,000 from her HSBC account in Mexico to the BOA 3349

4

Account.

5

Overt Act No. 216:

On or about May 2, 2018, an unknown

6

coconspirator fraudulently induced M.G. to send a wire transfer of

7

approximately $11,000 from her HSBC account in Mexico to a US Bank

8

account ending in 2910 of defendant AJAEZE in Inglewood, California.

9
10

Victim Company 13
Overt Act No. 217:

On or about July 9, 2017, defendant SAM MAL

11

asked defendant IRO to open a bank account in the name of a Chinese

12

company (“Chinese Company 2”).

13

Overt Act No. 218:

On or about July 11, 2017, defendant IRO

14

asked defendant UMEJESI to open a bank account at BOA or Citibank in

15

the name of Chinese Company 2.

16

Overt Act No. 219:

On or about July 11, 2017, following a

17

request by defendant IRO to open a bank account at Chase in the name

18

of Chinese Company 2, defendant CATHEY sent defendant IRO account

19

information for a Chase account ending in 5092 of UICC 16 opened in

20

the name of Chinese Company 2, in Hawthorne, California (the “Chase

21

5092 Account”).

22

Overt Act No. 220:

On or about July 12, 2017, following a

23

request by defendant IRO to open a bank account at Citibank or Wells

24

Fargo in the name of Chinese Company 2, defendant EKECHUKWU sent

25

defendant IRO account information for a Wells Fargo account ending in

26

4636 opened in the name of Chinese Company 2 (the “Wells Fargo 4636

27

Account”).

28
53

 1

Overt Act No. 221:

On or about July 17, 2017, defendant SAM MAL

2

told defendant IRO that Victim Company 13 would be making a payment

3

to Chinese Company 2, which defendant IRO then told defendant CATHEY

4

on or about July 18, 2017.

5

Overt Act No. 222:

On or about August 3, 2017, an unknown

6

coconspirator fraudulently induced Victim Company 13 to send a wire

7

transfer of approximately $382,295 from its account at Abu Dhabi

8

Commercial Bank in Dubai to the Chase 5092 Account.

9

Overt Act No. 223:

On or about August 5, 2017, defendants IRO

10

and CATHEY caused a cashier’s check of approximately $47,606.40

11

addressed to the name of a United Kingdom company to be purchased

12

from the Chase 5092 Account.

13

Overt Act No. 224:

On or about August 5, 2017, defendants IRO

14

and CATHEY caused a cashier’s check of approximately $52,602

15

addressed to the name of Chinese Company 1 to be purchased from the

16

Chase 5092 Account.

17

Overt Act No. 225:

On or about August 7, 2017, defendants IRO

18

and CATHEY caused a cashier’s check of approximately $65,965

19

addressed to UICC 10 to be purchased from the Chase 5092 Account.

20

Overt Act No. 226:

On or about August 8, 2017, defendants IRO

21

and CATHEY caused a cashier’s check of approximately $35,000

22

addressed to a name similar to an Indian company to be purchased from

23

the Chase 5092 Account.

24

Overt Act No. 227:

On or about August 9, 2017, defendants IRO

25

and CATHEY caused a cashier’s check of approximately $35,000

26

addressed to a name similar to an Indian company (“Indian Company 1”)

27

to be purchased from the Chase 5092 Account.

28
54

 1

Overt Act No. 228:

On or about August 10, 2017, defendants IRO

2

and CATHEY caused a cashier’s check of approximately $35,000

3

addressed to Indian Company 1 to be purchased from the Chase 5092

4

Account.

5

Overt Act No. 229:

On or about August 10, 2017, defendants IRO

6

and CATHEY caused approximately $60,000 to be sent through a wire

7

transfer from the Chase 5092 Account to defendant IGBOKWE’s BOA 2660

8

Account.

9

Overt Act No. 230:

On or about August 15, 2017, defendant

10

IGBOKWE sent a wire transfer of approximately $54,600 from his BOA

11

2660 Account to a Chase account ending in 9931 of defendant OGUNGBE,

12

dba “P and P Motors LLC” in Santa Fe Springs, California.

13

Overt Act No. 231:

On or about August 16, 2017, defendants IRO

14

and CATHEY caused a cashier’s check of approximately $35,000 to

15

Indian Company 1 to be deposited into a Chase account ending in 5812,

16

opened by UICC 16 in the name of Indian Company 1, in Inglewood,

17

California (the “Chase 5812 Account”).

18

Overt Act No. 232:

On or about August 22, 2017, defendants IRO

19

and CATHEY caused a cashier’s check of approximately $35,000 to

20

Indian Company 1 to be deposited into the Chase 5812 Account.

21
22

Victim Company 14
Overt Act No. 233:

On or about January 12, 2018, defendant

23

AJAEZE filed a Fictitious Business Name Statement with the Los

24

Angeles County Registrar-Recorder/County Clerk’s Office in the name

25

of a company in Mauritius (the “Mauritius Company”).

26
27

Overt Act No. 234:

On or about January 12, 2018, defendant

AJAEZE opened a bank account at Chase ending in 0038 with the name of

28
55

 1

the Mauritius Company as its business name, in Carson, California

2

(the “Chase 0038 Account”).

3

Overt Act No. 235:

On or about January 18, 2018, an unknown

4

coconspirator fraudulently induced Victim Company 14 to send a wire

5

transfer of approximately $76,688.99 from its account at Commerzbank

6

AG in Germany to defendant AJAEZE’s Chase 0038 Account.

7

Overt Act No. 236:

On or about January 19, 2018, defendant

8

AJAEZE sent a wire transfer of approximately $27,455 from the Chase

9

0038 Account to a Wells Fargo account in the name “Cadon Auto

10
11

Corporation.”
Overt Act No. 237:

On or about January 19, 2018, defendant

12

AJAEZE sent a wire transfer of approximately $51,865 from the Chase

13

0038 Account to a Mashreqbank PSC account in the United Arab Emirates

14

in the name “Elite Auto Fze.”

15

Overt Act No. 238:

On or about January 22, 2018, defendants IRO

16

and AJAEZE withdrew approximately $500 from the Chase 0038 Account

17

from an ATM in Los Angeles, California.

18

Overt Act No. 239:

On or about January 23, 2018, defendant

19

AJAEZE withdrew approximately $500 from the Chase 0038 Account from

20

an ATM in Carson, California.

21

Overt Act No. 240:

On or about January 30, 2018, an unknown

22

coconspirator fraudulently induced Victim Company 14 to send a wire

23

transfer of approximately $39,004.47 from its account at Commerzbank

24

AG in Germany to defendant AJAEZE’s Chase 0038 Account.

25

Overt Act No. 241:

On or about January 30, 2018, defendant

26

AJAEZE withdrew approximately $500 from the Chase 0038 Account from

27

an ATM in Los Angeles, California.

28
56

 1

Overt Act No. 242:

On or about February 1, 2018, defendant

2

AJAEZE purchased a cashier’s check of approximately $12,793 from the

3

Chase 0038 Account.

4

Overt Act No. 243:

On or about January 31, 2018, defendant

5

AJAEZE sent a wire transfer of approximately $19,000 from the Chase

6

0038 Account to the PNC Bank account of The George Washington

7

University, to pay the Spring 2018 tuition of a student.

8
9
10
11

Overt Act No. 244:

On or about February 5, 2018, defendant

AJAEZE withdrew approximately $2,000 from the Chase 0038 Account from
a Chase bank branch in Carson, California.
Overt Act No. 245:

On or about February 5, 2018, defendant

12

AJAEZE withdrew approximately $500 from the Chase 0038 Account from

13

an ATM in Carson, California.

14
15

Victim Company 15
Overt Act No. 246:

On or about February 13, 2018, defendant

16

AJAEZE filed a Fictitious Business Name Statement with the Los

17

Angeles County Registrar-Recorder/County Clerk’s Office in the name

18

of a Hong Kong-based company (“Chinese Company 3”).

19

Overt Act No. 247:

On or about February 13, 2018, defendant

20

AJAEZE added the name of Chinese Company 3 as a business name on the

21

Chase 0038 Account.

22

Overt Act No. 248:

On or about February 14, 2018, an unknown

23

coconspirator fraudulently induced Victim Company 15 to send a wire

24

transfer of approximately $886,950 from its account at PT Bank

25

Mandiri Tbk in Indonesia to defendant AJAEZE’s Chase 0038 Account.

26

Overt Act No. 249:

On or about February 15, 2018, defendant

27

AJAEZE sent a wire transfer of approximately $84,985 from the Chase

28

0038 Account to a BOA account ending in 5903.
57

 1

Overt Act No. 250:

On or about February 16, 2018, defendant

2

AJAEZE sent a wire transfer of approximately $189,000 from the Chase

3

0038 Account to a Compass Bank account ending in 3681 of defendant

4

IKOGHO, in Lynwood, California (the “Compass Bank 3681 Account”).

5

Overt Act No. 251:

On or about February 16, 2018, defendant

6

IKOGHO cashed a check for approximately $8,000 from the Compass Bank

7

3681 Account.

8
9
10
11

Overt Act No. 252:

On or about February 16, 2018, defendant

IKOGHO purchased a cashier’s check for approximately $35,000 from the
Compass Bank 3681 Account.
Overt Act No. 253:

On or about February 16, 2018, defendant

12

AJAEZE withdrew approximately $8,000 from the Chase 0038 Account from

13

a Chase bank branch in Carson, California.

14

Overt Act No. 254:

On or about February 17, 2018, defendant

15

AJAEZE withdrew approximately $500 from the Chase 0038 Account from

16

an ATM in Los Angeles, California.

17
18

Victim Company 16
Overt Act No. 255:

On or about January 22, 2018, defendant

19

AJAEZE opened a Wells Fargo account ending in 1849, in Carson,

20

California (the “Wells Fargo 1849 Account”).

21

Overt Act No. 256:

On or about February 13, 2018, defendant

22

AJAEZE filed a Fictitious Business Name Statement with the Los

23

Angeles County Registrar-Recorder/County Clerk’s Office in the name

24

of a Washington-based company (the “Washington Company”).

25

Overt Act No. 257:

On or about February 15, 2018, an unknown

26

coconspirator fraudulently induced Victim Company 16 to send a wire

27

transfer of approximately $1,750,000 from its account at National

28
58

 1

Westminster Bank PLC, in the United Kingdom, to defendant AJAEZE’s

2

Wells Fargo 1849 Account.

3

Overt Act No. 258:

On or about February 16, 2018, defendant

4

AJAEZE opened a Wells Fargo account ending in 7748, in Westchester,

5

California, in the name of the Washington Company (the “Wells Fargo

6

7748 Account”).

7

Overt Act No. 259:

On or about February 20, 2018, defendant

8

AJAEZE made a wire transfer of approximately $200,000 from the Wells

9

Fargo 1849 Account to the Wells Fargo 7748 Account.

10

Overt Act No. 260:

On or about February 20, 2018, defendant

11

AJAEZE made a wire transfer of approximately $500,000 from the Wells

12

Fargo 1849 Account to the Wells Fargo 7748 Account.

13

Overt Act No. 261:

On or about February 20, 2018, defendant

14

AJAEZE made a wire transfer of approximately $500,000 from the Wells

15

Fargo 1849 Account to the Wells Fargo 7748 Account.

16
17

Additional Overt Acts
Overt Act No. 262:

On or about October 7, 2014, defendant IRO

18

told defendant IZUNWANNE that he could get personal and company bank

19

accounts “everywhere,” including Malaysia, Indonesia, China, Hong

20

Kong, Italy, Germany, the United Kingdom, and India.

21

Overt Act No. 263:

On or about November 3, 2014, in response to

22

defendant IZUNWANNE’s request for a bank account in the Ukraine that

23

could receive the proceeds of a BEC fraud, defendant IRO negotiated

24

the rate that he would charge — telling defendant IZUNWANNE “what

25

matter is . . . making sure your money come out without any story” —

26

and sent defendant IZUNWANNE the account information, including the

27

account number and correspondent bank account number, for the Private

28

Bank Dnipropetrovsk account of P.N.M.
59

 1

Overt Act No. 264:

On or about December 4, 2014, defendant IRO

2

sent defendant ONWUASOANYA the account information, including the

3

account number and the routing number, for a BOA account ending in

4

8074, opened by defendant IRO dba “Iro Enterprises,” and defendants

5

IRO and ONWUASOANYA discussed the rates that defendant IRO would

6

charge for receiving and laundering the proceeds of BEC frauds and

7

romance scams.

8
9
10
11

Overt Act No. 265:

On or about March 29, 2016, defendant IRO

asked defendant ISAMADE to open a bank account with a specific
company name at Chase or US Bank, but not Bank of America.
Overt Act No. 266:

On or about November 21, 2016, defendant

12

IGBOKWE sent defendant EZIRIM the account information for the US Bank

13

2982 Account, including the name of UICC 2, the account number, and

14

the routing number.

15

Overt Act No. 267:

On or about January 2, 2017, defendant UGWU

16

requested a bank account that could receive an approximately $500,000

17

BEC fraud payment from Turkey.

18

Overt Act No. 268:

On or about January 2, 2017, defendant

19

IGBOKWE sent defendant IWU the account information for the US Bank

20

2669 Account, including the name of UICC 1, the account number, and

21

the routing number.

22

Overt Act No. 269:

On or about January 16, 2017, defendant

23

IGBOKWE sent defendant UBASINEKE the account information for a

24

SunTrust account ending in 8108 of UICC 18 (the “SunTrust 8108

25

Account”), including the name of UICC 18, the account number, and the

26

routing number, to use in receiving a $150,000 BEC fraud payment.

27
28

Overt Act No. 270:

On or about January 18, 2017, defendant

MEZIENWA told defendant IGBOKWE that he was using the SunTrust 8108
60

 1

Account that defendant IGBOKWE had provided to him, including the

2

name of UICC 18, the account number, and the routing number, to use

3

in receiving a $200,000 fraudulent payment.

4

Overt Act No. 271:

On or about January 18, 2017, in response to

5

defendant ODIONYENMA’s request for a bank account that could receive

6

an approximately $10,000 BEC fraud payment, defendant IGBOKWE sent

7

defendant ODIONYENMA the account information, including the name of

8

UICC 9, the account numbers, and the routing numbers, for the US Bank

9

0362 Account and the Wells Fargo 7245 Account.

10

Overt Act No. 272:

On or about January 21, 2017, in response to

11

defendant IKEWESI’s request for a bank account that could receive an

12

approximately $500,000 BEC fraud payment, defendant IGBOKWE sent

13

defendant IKEWESI the account information for a Wells Fargo account

14

ending in 1243 of UICC 17 (“Wells Fargo 1243 Account”) and for the US

15

Bank 0362 Account, including the account numbers and the routing

16

numbers.

17

Overt Act No. 273:

On or about January 21, 2017, in response to

18

defendant MEZIENWA’s request for a bank account that could receive an

19

approximately $3,000 fraudulent payment, defendant IGBOKWE sent

20

defendant MEZIENWA the account information for the Chase 7605

21

Account, including the account number and the routing number.

22

Overt Act No. 274:

On or about January 23, 2017, in response to

23

defendant NZENWAH’s request for a bank account that could receive an

24

approximately $250,000 BEC fraud payment, defendant IGBOKWE sent

25

defendant NZENWAH the account information for a TD Bank account

26

ending in 2396 of UICC 19 (the “TD Bank 2396 Account”), a Regions

27

Bank account ending in 6371 (the “Regions Bank 6371 Account”), and

28
61

 1

the SunTrust 8108 Account, including the account numbers and the

2

routing numbers.

3

Overt Act No. 275:

On or about January 24, 2017, in response to

4

defendant IBETO’s request for a bank account that could receive an

5

approximately $1,300 fraudulent payment, defendant IGBOKWE sent

6

defendant IBETO the account information for the Chase 7605 Account,

7

including the account number and the routing number.

8
9
10
11

Overt Act No. 276:

On or about January 25, 2017, defendant

MEGWA sent defendant IGBOKWE the account information for the US Bank
0362 Account, including the account number and the routing number.
Overt Act No. 277:

On or about January 25, 2017, defendant

12

IGBOKWE sent defendant IBETO the account information for the Wells

13

Fargo 7245 Account and the US Bank 0362 Account, including the

14

account numbers and the routing numbers, to use in receiving a

15

fraudulent payment.

16

Overt Act No. 278:

On or about January 26, 2017, defendant

17

MEGWA sent defendant IGBOKWE the account information for the Wells

18

Fargo 7245 Account, including the account number and the routing

19

number.

20

Overt Act No. 279:

On or about January 26, 2017, defendant

21

IGBOKWE sent defendant MEGWA the account information for the US Bank

22

0362 Account, including the account number and the routing number.

23

Overt Act No. 280:

On or about January 26, 2017, in response to

24

defendant IKEWESI’s request for a BOA account that could receive an

25

approximately $500,000 BEC fraud payment, defendant IGBOKWE sent

26

defendant IKEWESI the account information for a BOA account ending in

27

2942 of UICC 20 (the “BOA 2942 Account”), including the account

28

number and the routing number.
62

 1

Overt Act No. 281:

On or about January 26, 2017, in response to

2

defendant IKEWESI’s request for a bank account that could receive an

3

approximately $200,000 BEC fraud payment, defendant IGBOKWE sent

4

defendant IKEWESI the account information for the SunTrust 8108

5

Account, including the name of UICC 18, the account number, and the

6

routing number.

7

Overt Act No. 282:

On or about January 27, 2017, in response to

8

defendant C. DURU’s request for a bank account that could receive an

9

approximately $7,000 fraudulent payment, defendant IGBOKWE sent

10

defendant C. DURU the account information for the Chase 7605 Account,

11

including the account number and the routing number.

12

Overt Act No. 283:

On or about February 3, 2017, in response to

13

defendant AGUBE’s request for a bank account that could receive an

14

approximately $192,000 fraudulent payment, defendant IGBOKWE sent

15

defendant AGUBE the account information for the Chase 7605 Account,

16

including the account number and the routing number.

17

Overt Act No. 284:

On or about February 6, 2017, defendant

18

IGBOKWE sent defendant UGWU the account information for the US Bank

19

2982 Account, including the name of UICC 2, the account number, and

20

the routing number.

21

Overt Act No. 285:

On or about February 9, 2017, in response to

22

defendant OSUJI’s request for a bank account that could receive an

23

approximately $20,000 fraudulent payment, defendant IGBOKWE sent

24

defendant OSUJI the account information for the Chase 7605 Account,

25

including the account number and the routing number.

26

Overt Act No. 286:

On or about February 10, 2017, in response

27

to defendant UCHE’s request for a bank account that could receive an

28

approximately $50,000 romance scam payment, defendant IGBOKWE sent
63

 1

defendant UCHE the account information for the Chase 7605 Account,

2

including the account number and the routing number.

3

Overt Act No. 287:

On or about February 11, 2017, after

4

defendant IGBOKWE sent defendant MEGWA the account information for

5

the US Bank 0362 Account and two Wells Fargo Accounts — including the

6

account numbers and the routing numbers — defendant MEGWA told

7

defendant IGBOKWE that the US Bank account was “alive” but that the

8

Wells Fargo accounts had been closed.

9

Overt Act No. 288:

On or about February 13, 2017, in response

10

to defendant ONUDOROGU’s request for a bank account to receive an

11

approximately $6,000 fraudulent payment, defendant IGBOKWE sent

12

defendant ONUDOROGU the account information for the Chase 7605

13

Account, including the account number and the routing number.

14

Overt Act No. 289:

On or about February 15, 2017, defendant

15

IGBOKWE sent defendant IWUOHA the account information for the Chase

16

7605 Account, including the account number and the routing number,

17

for use in receiving fraudulent payments.

18

Overt Act No. 290:

On or about February 16, 2017, defendant

19

IGBOKWE sent defendant MEGWA the account information for the US Bank

20

2982 Account, including the name of UICC 2, the account number, and

21

the routing number.

22

Overt Act No. 291:

On or about February 20, 2017, in response

23

to defendant MARK CHUKWUOCHA’s request for a bank account that could

24

receive an approximately $146,000 fraudulent payment, defendant

25

IGBOKWE sent defendant MARK CHUKWUOCHA the account information for

26

the US Bank 0362 Account, including the account number and the

27

routing number.

28
64

 1

Overt Act No. 292:

On or about February 21, 2017, in response

2

to defendant MACWILLIAM CHUKWUOCHA’s request for a bank account that

3

could receive a fraudulent wire of approximately $100,000 from Qatar,

4

defendant IGBOKWE provided defendant MACWILLIAM CHUKWUOCHA the

5

account information for a Chase account ending in 3228 of UICC 21

6

(the “Chase 3228 Account”), including the account number and the

7

routing number.

8
9

Overt Act No. 293:

On or about February 21, 2017, after

defendant MARK CHUKWUOCHA told defendant IGBOKWE that approximately

10

$8,304.57 had been deposited to the Wells Fargo 1243 Account,

11

defendant IGBOKWE told him that the account had been closed due to

12

fraudulent transactions.

13

Overt Act No. 294:

On or about February 22, 2017, in response

14

to defendant OHAJIMKPO’s request for a credit card to use in

15

receiving approximately $850,000 in fraudulent funds, defendant

16

IGBOKWE responded, in part, “if use my card FBI will come 4 me.”

17

Overt Act No. 295:

On or about February 23, 2017, in response

18

to defendant EJIOFOR’s request for a bank account that could receive

19

an approximately $16,000 fraudulent payment, defendant IGBOKWE sent

20

defendant EJIOFOR the account information for the Wells Fargo 7245

21

Account, including the name of UICC 9, the account number, and the

22

routing number.

23

Overt Act No. 296:

On or about February 24, 2017, in response

24

to defendant EZIRIM’s request for a bank account that could receive

25

an approximately $100,000 BEC fraud payment from Korea, defendant

26

IGBOKWE provided defendant EZIRIM the account information for the

27

Chase 3228 Account, including the account number and the routing

28

number.
65

 1

Overt Act No. 297:

On or about February 25, 2017, defendant IRO

2

sent defendant CHUKWU the account information for a Wells Fargo

3

account ending in 6969 of defendant EKECHUKWU (the “Wells Fargo 6969

4

Account”), including the account number and the routing number.

5

Overt Act No. 298:

On or about February 28, 2017, in response

6

to defendant UCHE’s request for a bank account that could receive an

7

approximately $60,000 fraudulent payment, defendant IGBOKWE sent

8

defendant UCHE the account information for the US Bank 0362 Account,

9

including the account number and the routing number.

10

Overt Act No. 299:

On or about March 1, 2017, defendant UMEJESI

11

sent defendant IGBOKWE the account information for the US Bank 0362

12

Account, including the account number and the routing number.

13

Overt Act No. 300:

On or about March 1, 2017, defendant IGBOKWE

14

sent defendant UCHE the account information for the US Bank 0362

15

Account, including the account number and the routing number.

16

Overt Act No. 301:

On or about March 1, 2017, defendant IGBOKWE

17

sent defendant UCHE the account information for the US Bank 2982

18

Account, including the name of UICC 2, the account number, and the

19

routing number.

20

Overt Act No. 302:

On or about March 1, 2017, in response to a

21

request by defendant OFORKA in coded language for a bank account that

22

could receive a fraudulent payment of approximately $28,000,

23

defendant IRO sent defendant OFORKA the account information for the

24

Wells Fargo 6969 Account, including the account number and the

25

routing number.

26

Overt Act No. 303:

On or about March 2, 2017, defendant IGBOKWE

27

sent defendant IWU the account information for a Wells Fargo account

28

ending in 6307 of UICC 2 (the “Wells Fargo 6307 Account”), including
66

 1

the account number and the routing number, to receive fraudulent

2

payments.

3

Overt Act No. 304:

On or about March 3, 2017, in response to

4

defendant MBA’s request for a bank account that could receive an

5

approximately $32,000 BEC fraud payment, defendant IGBOKWE sent

6

defendant MBA the account information for the Wells Fargo 6307

7

Account, including the account number and the routing number.

8
9

Overt Act No. 305:

On or about March 5, 2017, defendant IGBOKWE

sent defendant OHAJIMKPO the account information for the Wells Fargo

10

7245 Account, including the name of UICC 9, the account number, and

11

the routing number.

12

Overt Act No. 306:

On or about March 6, 2017, in response to

13

defendant MBA’s request for a bank account that could receive an

14

approximately $25,000 BEC fraud payment, defendant IGBOKWE sent

15

defendant MBA the account information for the Wells Fargo 7245

16

Account, including the name of UICC 9, the account number, and the

17

routing number.

18

Overt Act No. 307:

On or about March 6, 2017, in response to

19

defendant CHUKWU’s request for a bank account that could receive an

20

approximately $50,000 romance scam payment, defendant IGBOKWE sent

21

defendant CHUKWU the account information for the BOA 2942 Account,

22

including the account number and the routing number.

23

Overt Act No. 308:

On or about March 6, 2017, defendant IGBOKWE

24

told defendant IWU that he could use the Wells Fargo 6307 Account to

25

receive a romance scam payment.

26

Overt Act No. 309:

On an unknown date, no later than March 7,

27

2017, defendant UKACHUKWU gave defendant AGWUEGBO the phone number of

28

defendant IGBOKWE.
67

 1

Overt Act No. 310:

On or about March 7, 2017, after defendant

2

AGWUEGBO told defendant IGBOKWE that he needed Wells Fargo accounts

3

to receive BEC fraud payments from China, defendant IGBOKWE sent

4

defendant AGWUEGBO the account information for a US Bank account

5

ending in 9570 (“US Bank 9570 Account), including the account number

6

and the routing number.

7

Overt Act No. 311:

On or about March 7, 2017, defendant IGBOKWE

8

sent defendant UCHE the account information for the US Bank 9570

9

Account, including the account number and the routing number.

10

Overt Act No. 312:

On or about March 9, 2017, in response to

11

defendant MADUFOR’s request for a bank account that could receive an

12

approximately $130,000 fraudulent payment, defendant IGBOKWE sent

13

defendant MADUFOR the account information for the TD Bank 2396

14

Account, including the account number and the routing number.

15

Overt Act No. 313:

On or about March 10, 2017, in response to

16

defendant OKORIE’s request for a bank account that could receive an

17

approximately $9,000 romance scam payment, defendant IGBOKWE sent

18

defendant OKORIE the account information for the Chase 7605 Account,

19

including the account number and the routing number.

20

Overt Act No. 314:

On or about March 10, 2017, defendant

21

IGBOKWE sent defendant IBETO the account information for the US Bank

22

9570 Account, including the account number and the routing number.

23

Overt Act No. 315:

On or about March 10, 2017, defendant

24

IGBOKWE sent defendant EJIOFOR the account information for the Chase

25

3228 Account, including the account number and the routing number, to

26

use in receiving a fraudulent transaction.

27
28
68

 1

Overt Act No. 316:

On or about March 14, 2017, defendant

2

IGBOKWE sent defendant UMEJESI the account information for the BOA

3

4859 Account, including the account number and the routing number.

4

Overt Act No. 317:

On or about March 14, 2017, defendant

5

IGBOKWE sent defendant ISAMADE the account information for the BOA

6

4859 Account, including the account number and the routing number, to

7

receive romance scam payments, which defendant ISAMADE expected to

8

total approximately $59,000.

9

Overt Act No. 318:

On or about March 14, 2017, in response to

10

defendant AGWUEGBO’s request for a bank account that could receive an

11

approximately $100,000 fraudulent transaction, defendant IGBOKWE sent

12

defendant AGWUEGBO the account information for the US Bank 0362

13

Account, including the account number and the routing number.

14

Overt Act No. 319:

On or about March 16, 2017, in response to

15

defendant UCHE’s request for a bank account that could receive a

16

fraudulent payment of approximately $1,300,000 from Tanzania,

17

defendant IGBOKWE provided defendant UCHE the account information for

18

the Chase 5027 Account, including the account number and the routing

19

number.

20

Overt Act No. 320:

On or about March 16, 2017, defendant

21

IGBOKWE sent defendant UKACHUKWU the account information for the BOA

22

4859 Account, including the account number and the routing number.

23

Overt Act No. 321:

On or about March 16, 2017, defendant

24

IGBOKWE sent defendant MBA the account information for the Wells

25

Fargo 7245 Account, including the account number and the routing

26

number.

27
28

Overt Act No. 322:

On or about March 16, 2017, in response to

defendant OHIRI’s request for a bank account that could receive an
69

 1

approximately $5,000 romance scam payment, defendant IGBOKWE sent

2

defendant OHIRI the account information for the US Bank 2982 Account,

3

including the account number and the routing number.

4

Overt Act No. 323:

On or about March 17, 2017, defendant

5

UMEJESI sent defendant IRO the account information for the Wells

6

Fargo 7245 Account, including the account number and the routing

7

number.

8
9

Overt Act No. 324:

On or about March 17, 2017, in response to

defendant OKAFOR’s request for a bank account that could receive an

10

approximately $88,000 BEC fraud payment, defendant IRO sent defendant

11

OKAFOR the account information for the Wells Fargo 7245 Account,

12

including the account number and the routing number.

13

Overt Act No. 325:

On or about March 20, 2017, defendant

14

IGBOKWE sent defendant ONUWA the account information for the Chase

15

5027 Account, including the name of UICC 1, the account number, and

16

the routing number.

17

Overt Act No. 326:

On or about March 21, 2017, in response to

18

defendant OGBONNA’s request for a bank account that could receive an

19

approximately $700,000 romance scam payment, defendant IRO sent

20

defendant OGBONNA the account information for the Chase 5027 Account,

21

including the account number and the routing number.

22

Overt Act No. 327:

On or about March 21, 2017, defendant IRO

23

sent defendant OKAFOR the account information for the Chase 5027

24

Account, including the account number and the routing number, for use

25

in a romance scam scheme.

26
27

Overt Act No. 328:

On or about March 22, 2017, defendant IRO

sent defendant OGUNGBE the account information for the Chase 5027

28
70

 1

Account, including the account number and the routing number, to

2

receive an approximately $3,000,000 transaction from the Philippines.

3

Overt Act No. 329:

On or about March 23, 2017, defendant IRO

4

sent defendant ANOZIE an audio recording of himself on the phone with

5

a Chase representative, in which defendant IRO purported to be

6

defendant IGBOKWE while inquiring about a Chase account ending in

7

0595, opened by defendant IGBOKWE.

8
9
10
11

Overt Act No. 330:

On or about March 29, 2017, defendant NNAMDI

DURU created an email account at the request of defendant IRO, which
email account used the name of UICC 25.
Overt Act No. 331:

On or about March 29, 2017, in response to

12

defendant OKAFOR’s request for a bank account that could receive an

13

approximately $100,000 BEC fraud payment, defendant IRO sent

14

defendant OKAFOR the account information for a BOA account ending in

15

0358 (the “BOA 0358 Account”), including the account number and the

16

routing number.

17

Overt Act No. 332:

On or about March 30, 2017, defendant

18

IGBOKWE sent defendant OBASI the account information for a Citibank

19

account ending in 0126 of UICC 2, including the account number and

20

the routing number, to receive a BEC fraud payment.

21

Overt Act No. 333:

On or about April 2, 2017, in response to

22

defendant ANYANWU’s request for a bank account that could receive

23

approximately $59,000 in BEC fraud payments, defendant IRO sent

24

defendant ANYANWU the account information for a Wells Fargo account

25

ending in 7276 of UICC 21 (the “Wells Fargo 7276 Account”), including

26

the account number and the routing number.

27
28

Overt Act No. 334:

On or about April 2, 2017, in response to

defendant OBASI’s request for a bank account that could receive an
71

 1

approximately $159,000 BEC fraud payment, defendant IGBOKWE sent

2

defendant OBASI the account information for the Wells Fargo 7276

3

Account, including the account number and the routing number.

4

Overt Act No. 335:

On or about April 3, 2017, defendant IRO

5

sent defendant NNAMDI DURU photographs of banking documents in the

6

name of UICC 25, including the Chase 7866 Account and the Chase 9927

7

Account.

8
9

Overt Act No. 336:

On or about April 3, 2017, in response to

defendant OKAFOR’s request for a bank account that could receive an

10

approximately $70,000 BEC fraud payment, defendant IRO sent defendant

11

OKAFOR the account information for a BOA account ending in 8560 of

12

UICC 10 in Forest Park, Georgia (the “BOA 8560 Account”), including

13

the account number and the routing number.

14

Overt Act No. 337:

On or about April 3, 2017, defendant IRO

15

assisted defendant NNAMDI DURU in purchasing a list of email

16

addresses of real estate agents in New York State for use in sending

17

emails intended to disseminate malicious software in furtherance of

18

fraudulent schemes.

19

Overt Act No. 338:

On or about April 3, 2017, in response to

20

defendant OHAJIMKPO’s request for a bank account that could receive

21

an approximately $98,000 BEC fraud payment from China, defendant

22

IGBOKWE sent defendant OHAJIMKPO the account information for the BOA

23

1004 Account, including the account number and the routing number.

24

Overt Act No. 339:

On or about April 4, 2017, defendant OJIMBA

25

opened a bank account at the request of defendant IRO, and assured

26

defendant IRO that his work for defendant would remain a “secret.”

27
28

Overt Act No. 340:

On or about April 4, 2017, in response to

defendant OFORKA’s request in coded language for a bank account that
72

 1

could receive an approximately $600,000 BEC fraud payment, with total

2

anticipated BEC fraud payments of approximately $12,000,000,

3

defendant IRO sent defendant OFORKA the account information for a BOA

4

account ending in 4560 of UICC 22 (the “BOA 4560 Account”), including

5

the account number and the routing number.

6

Overt Act No. 341:

On or about April 4, 2017, in response to

7

defendant NNAMDI DURU’s request for a bank account that could receive

8

a fraudulent payment of approximately $1,700,000 from Dubai,

9

defendant IRO sent defendant NNAMDI DURU the account information for

10

the BOA 8560 Account, including the account number and the routing

11

number.

12

Overt Act No. 342:

On or about April 7, 2017, in response to

13

defendant OHAJIMKPO’s request for a bank account to receive an

14

approximately $150,000 romance scam payment, defendant IGBOKWE sent

15

defendant OHAJIMKPO the account information for the Chase 5027

16

Account, including the account number and the routing number.

17

Overt Act No. 343:

On or about April 10, 2017, defendant NNAMDI

18

DURU told defendant IRO about a Brazilian company that would be

19

making a fraudulent payment.

20

Overt Act No. 344:

On or about April 12, 2017, defendant

21

IGBOKWE sent defendant MBA the account information for the Wells

22

Fargo 4899 Account of defendant P. DURU, including the account number

23

and the routing number, and told defendant MBA to use the bank

24

account for “big money.”

25

Overt Act No. 345:

On or about April 12, 2017, in response to

26

defendant ANYANWU’s request for a bank account that could receive an

27

approximately $100,000 BEC fraud payment, defendant IRO sent

28
73

 1

defendant ANYANWU the account information for the BOA 8560 Account,

2

including the account number and the routing number.

3

Overt Act No. 346:

On or about April 12, 2017, in response to

4

defendant ANYANWU’s request for a bank account that could receive an

5

approximately $80,000 romance scam payment, defendant IRO sent

6

defendant ANYANWU the account information for the Chase 7866 Account,

7

including the name of UICC 25, the account number, and the routing

8

number.

9

Overt Act No. 347:

On or about April 12, 2017, in response to

10

defendant E. DIKE’s request for a bank account that could receive

11

approximately $3,000 in romance scam payments, defendant IRO sent

12

defendant E. DIKE the account information for the Chase 7866 Account,

13

including the name of UICC 25, the account number, and the routing

14

number.

15

Overt Act No. 348:

On or about April 13, 2017, defendant

16

ODIMARA asked defendant IGBOKWE for multiple bank accounts to receive

17

fraudulent payments totaling more than $450,000.

18

Overt Act No. 349:

On or about April 13, 2017, in response to a

19

request from defendant AWAK for a bank account that could receive the

20

proceeds of a romance scam, defendant IRO sent defendant AWAK the

21

account information for the Chase 7866 Account, including the name of

22

UICC 25, the account number, and the routing number.

23

Overt Act No. 350:

On or about April 13, 2017, defendant OJIMBA

24

sent defendant IRO the account information for a BOA account ending

25

in 7032 of UICC 22 (the “BOA 7032 Account”), including the name of

26

UICC 22, the account number, and the routing number, and asked

27

defendant IRO not to use that account again because BOA told UICC 22

28

it was investigating the account.
74

 1

Overt Act No. 351:

On or about April 13, 2017, defendant IRO

2

advised defendant OJIMBA to attempt to reopen the BOA 7032 Account at

3

Chase or US Bank, and to use the same business name as the BOA 7032

4

Account.

5

Overt Act No. 352:

On or about April 14, 2017, defendant OJIMBA

6

sent defendant IRO the account information for a US Bank account

7

ending in 1789 (the “US Bank 1789 Account”), including the name of

8

UICC 22, the account number, and the routing number.

9

Overt Act No. 353:

On or about April 14, 2017, after defendant

10

NNAMDI DURU requested a bank account that could receive $200,000,000

11

in fraudulent funds, defendant IRO sent defendant NNAMDI DURU the

12

account information for the BOA 8560 Account and the Wells Fargo 4899

13

Account, but then sent the account information for the Chase 5027

14

Account, which defendant IRO said was “stronger.”

15

Overt Act No. 354:

On or about April 14, 2017, defendant

16

IGBOKWE sent defendant OCHIAGHA the account information for the Wells

17

Fargo 4899 Account and the BOA 1004 Account, including the account

18

numbers and the routing numbers, and told defendant OCHIAGHA that the

19

BOA 1004 Account could be used to receive a BEC fraud payment.

20

Overt Act No. 355:

On or about April 16, 2017, in response to

21

defendant OGBONNA’s request for a bank account that could receive an

22

approximately $25,000 romance scam payment, defendant IRO sent

23

defendant OGBONNA the account information for the Chase 7866 Account,

24

including the name of UICC 25, the account number, and the routing

25

number.

26

Overt Act No. 356:

On or about April 16, 2017, in response to

27

defendant CHIKA’s request for a bank account that could receive an

28

approximately $10,000 romance scam payment, defendant IRO sent
75

 1

defendant CHIKA the account information for the Chase 7866 Account,

2

including the name of UICC 25, the account number, and the routing

3

number.

4

Overt Act No. 357:

On or about April 17, 2017, after defendant

5

CHILAKA requested a bank account that could receive the proceeds of a

6

BEC fraud, defendant IGBOKWE sent defendant CHILAKA the account

7

information for the BOA 4859 Account, including the account number

8

and the routing number.

9

Overt Act No. 358:

On or about April 20, 2017, defendant

10

IGBOKWE sent defendant UMEJESI the account information for the Wells

11

Fargo 4899 Account, including the account number and the routing

12

number.

13

Overt Act No. 359:

On or about April 20, 2017, defendant

14

IGBOKWE sent defendant UZOKA the account information for the Wells

15

Fargo 4899 Account, including the account number and the routing

16

number.

17

Overt Act No. 360:

On or about April 20, 2017, defendant

18

IGBOKWE sent defendant ODIONYENMA the account information for the

19

Wells Fargo 4899 Account, including the account number and the

20

routing number.

21

Overt Act No. 361:

On or about April 24, 2017, defendant

22

IGBOKWE sent defendant ONUWA the account information for the Chase

23

5027 Account, including the name of UICC 1, the account number, and

24

the routing number.

25

Overt Act No. 362:

On or about April 24, 2017, in response to

26

defendant MADUFOR’s request for a bank account that could receive an

27

approximately $150,000 BEC fraud payment, defendant IGBOKWE sent

28

defendant MADUFOR the account information for the Wells Fargo 4899
76

 1

Account and the BOA 1004 Account, including the account numbers and

2

the routing numbers.

3

Overt Act No. 363:

On or about April 25, 2017, defendant IRO

4

told defendant OJIMBA to “start servicing” the US Bank 1789 account

5

because he was expecting a payment of approximately $1,700,000 to

6

arrive in the account.

7

Overt Act No. 364:

On or about April 25, 2017, in response to a

8

request from defendant ISAMADE for a bank account that could receive

9

a BEC fraud payment, defendant IGBOKWE sent defendant ISAMADE the

10

account information for a Wells Fargo account ending in 5309 of UICC

11

23 (“Wells Fargo 5309 Account”), including the name of UICC 23, the

12

account number, and the routing number.

13

Overt Act No. 365:

On or about April 25, 2017, defendant

14

IGBOKWE sent defendant NNEBEDUM the account information for the Wells

15

Fargo 5309 Account, including the account-holder’s name, the account

16

number, and the routing number, to receive fraudulent transactions

17

totaling approximately $157,000.

18

Overt Act No. 366:

On or about April 27, 2017, defendant

19

IGBOKWE sent defendant UGWU the account information for the BOA 1004

20

Account, including the name of UICC 11, the account number, and the

21

routing number.

22

Overt Act No. 367:

On or about April 28, 2017, defendants

23

ODIMARA and IGBOKWE discussed a fraudulent payment of approximately

24

$36,274 made to the Wells Fargo 7276 Account.

25

Overt Act No. 368:

On or about April 29, 2017, defendant

26

IGBOKWE sent defendant ONYEKA the account information for the US Bank

27

0362 Account, including the account number and the routing number.

28
77

 1

Overt Act No. 369:

On or about May 2, 2017, in response to

2

defendant OKOLO’s request for a bank account that could receive an

3

approximately $766,000 BEC fraud payment, defendant IGBOKWE sent

4

defendant OKOLO the account information for the Chase 5899 Account,

5

including the account number and the routing number.

6

Overt Act No. 370:

On or about May 4, 2017, defendant IRO sent

7

defendant E. DIKE the account information for the BOA 2660 Account,

8

including the account number and the routing number, for use in

9

receiving a romance scam payment and told him how to avoid having his

10

victim learn the money would be deposited to a bank account in

11

California.

12

Overt Act No. 371:

On or about May 5, 2017, defendant IGBOKWE

13

sent defendant ONUWA the account information for the Chase 5027

14

Account, including the name of UICC 1, the account number, and the

15

routing number.

16

Overt Act No. 372:

On or about May 8, 2017, in response to a

17

request from defendant UZOKA for a bank account that could receive an

18

approximately $300,000 BEC fraud payment, defendant IGBOKWE sent

19

defendant UZOKA the account information for the Chase 5899 Account,

20

including the account number and the routing number.

21

Overt Act No. 373:

On or about May 15, 2017, in response to

22

defendant ONWUASOANYA’s request for a bank account that could receive

23

a romance scam payment totaling approximately $200,000, defendant IRO

24

sent defendant ONWUASOANYA the account information for defendant

25

IGBOKWE’s BOA 2660 Account, including the account number and the

26

routing number.

27
28

Overt Act No. 374:

On or about May 17, 2017, in response to a

request by defendant AZUBUIKE for a bank account that could receive
78

 1

an approximately $70,000 romance scam payment, defendant IGBOKWE sent

2

defendant AZUBUIKE the account information for a Wells Fargo account

3

ending in 4216 (the “Wells Fargo 4216 Account”), including the name

4

of UICC 22, the account number, and the routing number.

5

Overt Act No. 375:

On or about May 17, 2017, defendant IGBOKWE

6

sent defendant UGWU the account information for a Chase account

7

ending in 3995 of UICC 22 (the “Chase 3995 Account”), including the

8

name of UICC 22, the account number, and the routing number.

9

Overt Act No. 376:

On or about May 17, 2017, in response to

10

defendant OKEREKE’s request for a bank account that could receive an

11

approximately $35,000 romance scam payment, defendant IGBOKWE sent

12

defendant OKEREKE the account information for the Wells Fargo 1147

13

Account, including the account number and the routing number.

14

Overt Act No. 377:

On or about May 17, 2017, defendant IGBOKWE

15

sent defendant OKEREKE the account information for the Chase 5027

16

Account, including the name of UICC 1, the account number, and the

17

routing number, to receive an approximately $2,000 romance scam

18

payment.

19

Overt Act No. 378:

On or about May 19, 2017, in response to a

20

request by defendant UZOKA for a bank account that could receive an

21

approximately $350,000 romance scam payment, defendant IGBOKWE sent

22

defendant UZOKA the account information for the Chase 7605 Account,

23

including the name the account number and the routing number.

24

Overt Act No. 379:

On or about May 23, 2017, defendant AGUH

25

told defendant IGBOKWE that he was using the BOA 2660 Account that

26

defendant IGBOKWE had provided to him, including the account number,

27

and the routing number, to use in receiving a fraudulent payment.

28
79

 1

Overt Act No. 380:

On or about May 23, 2017, defendants IRO and

2

EKI discussed whether the Chase 7866 Account had received a

3

fraudulent payment.

4

Overt Act No. 381:

On or about May 26, 2017, in response to

5

defendant OFORKA’s request for a bank account that could receive a

6

fraudulent payment of approximately $100,000, defendant IRO sent

7

defendant OFORKA the account information for the Chase 5027 Account,

8

including the account number and the routing number.

9

Overt Act No. 382:

On or about May 29, 2017, in response to

10

defendant OKOLO’s request for a bank account that could receive an

11

approximately $92,000 BEC fraud payment, defendant IGBOKWE sent

12

defendant OKOLO the account information for the Wells Fargo 5309

13

Account and the Chase 3995 Account, including the account numbers and

14

the routing numbers.

15

Overt Act No. 383:

On or about June 1, 2017, defendant IGBOKWE

16

sent defendant ODIMARA the account information for the Wells Fargo

17

5309 Account, including the account number and the routing number.

18

Overt Act No. 384:

On or about June 1, 2017, in response to

19

defendant OSUJI’s request for a bank account that could receive an

20

approximately $4,000 fraudulent payment, defendant IGBOKWE sent

21

defendant OSUJI the account information for the Chase 7605 Account,

22

including the name of UICC 1, the account number, and the routing

23

number.

24

Overt Act No. 385:

On or about June 2, 2017, defendant IGBOKWE

25

sent defendant ONUDOROGU the account information for the BOA 2660

26

Account, including the account number and the routing number, to use

27

in receiving a fraudulent payment of approximately $12,593.

28
80

 1

Overt Act No. 386:

On or about June 3, 2017, defendant IGBOKWE

2

sent defendant NWANEGWO the account information for the Chase 7605

3

Account, including the name of UICC 1, the account number, and the

4

routing number, for use in receiving a fraudulent transaction.

5

Overt Act No. 387:

On or about June 6, 2017, in response to

6

defendant G. DIKE’s request for a bank account that could receive an

7

approximately $100,000 fraudulent payment, defendant IGBOKWE sent

8

defendant G. DIKE the account information for the BOA 7032 Account,

9

including the account number and the routing number.

10

Overt Act No. 388:

On or about June 7, 2017, in response to a

11

request by defendant AZUBUIKE for a bank account that could receive

12

an approximately $50,000 BEC fraud payment, defendant IGBOKWE sent

13

defendant AZUBUIKE the account information for the Wells Fargo 4216

14

Account, including the account number and the routing number.

15

Overt Act No. 389:

On or about June 7, 2017, in response to

16

defendant OFORKA’s request for a bank account that could receive an

17

approximately $5,000 romance scam payment, defendant IGBOKWE sent

18

defendant OFORKA the account information for the Chase 5027 Account,

19

including the account number and the routing number.

20

Overt Act No. 390:

On or about June 8, 2017, in response to

21

defendant EZIRIM’s request for a bank account that could receive an

22

approximately $100,000 fraudulent payment, defendant IGBOKWE provided

23

defendant EZIRIM the account information for the Chase 5027 Account,

24

including the account number and the routing number.

25
26

Overt Act No. 391:

On or about June 8, 2017, defendants IRO and

OKAFOR discussed the closure of the Wells Fargo 4216 Account.

27
28
81

 1

Overt Act No. 392:

On or about June 9, 2017, defendant IGBOKWE

2

sent defendant OFORKA the account information for the US Bank 0362

3

Account, including the account number and the routing number.

4

Overt Act No. 393:

On or about June 11, 2017, defendant IGBOKWE

5

sent defendant ODIMARA the account information for the Chase 7605

6

Account, including name of UICC 1, the account number, and the

7

routing number.

8
9

Overt Act No. 394:

On or about June 12, 2017, in response to

defendant ONYEKA’s request for a bank account that could receive a

10

BEC fraud payment, defendant IGBOKWE sent defendant ONYEKA the

11

account information for the BOA 1004 Account, including the account

12

number and the routing number.

13

Overt Act No. 395:

On or about June 13, 2017, in response to

14

defendant AWAK’s request for a bank account that could receive an

15

approximately $50,000 romance scam payment, defendant IRO sent

16

defendant AWAK the account information for the BOA 2660 Account,

17

including the account number and the routing number.

18

Overt Act No. 396:

On or about June 13, 2017, defendant IGBOKWE

19

sent defendant NWANEGWO the account information for the BOA 2660

20

Account, including the account number and the routing number, to use

21

in receiving a fraudulent payment.

22

Overt Act No. 397:

On or about June 15, 2017, in response to

23

defendant OFORKA’s request for a bank account that could receive a

24

fraudulent payment of approximately $18,000, defendant IGBOKWE sent

25

defendant OFORKA the account information for the Chase 5027 Account,

26

including the account number and the routing number.

27
28

Overt Act No. 398:

On or about June 17, 2017, defendant IGBOKWE

sent defendant ESHIMBU the account information for the BOA 2660
82

 1

Account, including the account number and the routing number, to use

2

in receiving a fraudulent payment.

3

Overt Act No. 399:

On or about June 18, 2017, in response to a

4

request by defendant EGWUMBA for a Chase bank account that could

5

receive an approximately $2,000,000 fraudulent wire, defendant IRO

6

sent defendant EGWUMBA the account information for the Chase 5027

7

Account, including the account number and the routing number, and

8

told defendant EGWUMBA that the coconspirator conducting the fraud

9

would receive 40% of the proceeds, that the person who opened the

10

bank account would receive 40%, and that defendants IRO and EGWUMBA

11

would split the remaining 20%.

12

Overt Act No. 400:

On or about June 18, 2017, in response to

13

defendant OHIRI’s

14

approximately $500,000 BEC fraud payment, defendant IGBOKWE sent

15

defendant OHIRI the account information for a Citizens Bank account

16

ending in 7430 (the “Citizens Bank 7430 Account”), including the

17

account number and the routing number.

18

request for a bank account that could receive an

Overt Act No. 401:

On or about June 19, 2017, in response to

19

defendant OGANDU’s request for a bank account that could receive an

20

approximately $50,000 romance scam payment, defendant IGBOKWE sent

21

defendant OGANDU the account information for the Chase 7605 Account,

22

including the name of UICC 1, the account number, and the routing

23

number.

24

Overt Act No. 402:

On or about June 19, 2017, in response to a

25

request by defendant NWACHUKWU for a bank account that could receive

26

an approximately $130,000 fraudulent payment, defendant IRO sent

27

defendant NWACHUKWU the account information for the Chase 5027

28

Account, including the account number and the routing number.
83

 1

Overt Act No. 403:

On or about June 21, 2017, defendant IRO

2

told defendant NNAMDI that the exchange rate that defendant IRO

3

provided was low given that his money exchangers provided a low

4

exchange rate to him because they helped “clean” the funds.

5

Overt Act No. 404:

On or about June 22, 2017, defendant IGBOKWE

6

sent defendant AGWUEGBO the account information for the Wells Fargo

7

5309 Account, including the name of UICC 23, the account number, and

8

the routing number.

9

Overt Act No. 405:

On or about June 22, 2017, defendant IGBOKWE

10

sent defendant IWUOHA the account information for the BOA 2660

11

Account, including the account number and the routing number, to use

12

in receiving a fraudulent payment.

13

Overt Act No. 406:

On or about June 25, 2017, defendant AGUH

14

told defendant IGBOKWE that he was using the Chase 7605 Account that

15

defendant IGBOKWE had provided to him, including the name of UICC 1,

16

the account number, and the routing number, to use in receiving a

17

fraudulent payment.

18

Overt Act No. 407:

On or about June 26, 2017, in response to

19

defendant G. DIKE’s request for a MoneyGram account that could

20

receive a fraudulent payment, defendant IGBOKWE sent defendant

21

G. DIKE the name of UICC 1.

22

Overt Act No. 408:

On or about June 27, 2017, after defendant

23

OSMUND asked for a bank account that could receive romance scam

24

funds, defendant IGBOKWE sent defendant OSMUND the account

25

information for the Chase 7605 Account, including the account number

26

and the routing number.

27

Overt Act No. 409:

28

On or about June 28, 2017, in response to a

request by defendant OGANDU for a bank account that could receive an
84

 1

approximately 43,000 euro BEC payment, defendant IGBOKWE sent

2

defendant OGANDU the account information for the BOA 7032 Account,

3

including the name of UICC 22, the account number, and the routing

4

number; and the Chase 7003 Account, including the account number and

5

the routing number.

6

Overt Act No. 410:

On or about June 28, 2017, in response to

7

defendant ONYEKA’s request for a bank account that could receive an

8

approximately $200,000 BEC fraud payment, defendant IGBOKWE sent

9

defendant ONYEKA the account information for a BOA account ending in

10

0307 (the “BOA 0307 Account”), including the account number and the

11

routing number.

12

Overt Act No. 411:

On or about June 29, 2017, in response to a

13

request by defendant EGWUMBA for a bank account that could receive a

14

BEC fraud payment, defendant IRO sent defendant EGWUMBA the account

15

information for the US Bank 1789 Account, including the name of

16

UICC 22, the account number, and the routing number.

17

Overt Act No. 412:

On or about July 2, 2017, in response to a

18

request by defendant NWACHUKWU for a bank account that could receive

19

an approximately $3,000 romance scam payment, defendant IRO sent

20

defendant NWACHUKWU the account information for a BOA account ending

21

in 0305 (the “BOA 0305 Account”), including the name of UICC 25, the

22

account number, and the routing number.

23

Overt Act No. 413:

On or about July 5, 2017, defendant IRO sent

24

defendant CHIKA the account information for the BOA 3563 Account,

25

including the account number and the routing number, and the account

26

information for the BOA 0305 Account, including the name of UICC 25,

27

the account number, and the routing number, for use in receiving

28

romance scam payments.
85

 1

Overt Act No. 414:

On or about July 5, 2017, defendant IRO sent

2

defendant EKI the account information for the BOA 3563 Account,

3

including the account number and the routing number, and the account

4

information for the BOA 0305 Account, including the name of UICC 25,

5

the account number, and the routing number, for use in receiving

6

romance scam payments.

7

Overt Act No. 415:

On or about July 6, 2017, in response to a

8

request by defendant AZUBUIKE for a bank account that could receive

9

an approximately $370,000 payment, defendant IGBOKWE sent defendant

10

AZUBUIKE the account information for four BOA accounts, including the

11

account numbers and the routing numbers.

12

Overt Act No. 416:

On or about July 7, 2017, in response to

13

defendant AJAH’s request for a bank account that could receive

14

approximately $15,000 in romance scam payments, defendant IRO sent

15

defendant AJAH the account information for the BOA 0305 Account,

16

including the name of UICC 25, the account number, and the routing

17

number, and the BOA 3563 Account, including the account number and

18

the routing number.

19

Overt Act No. 417:

On or about July 8, 2017, defendant IGBOKWE

20

sent defendant IHEJIUREME the account information for a Wells Fargo

21

account ending in 0848, to use in receiving a fraudulent payment.

22

Overt Act No. 418:

On or about July 9, 2017, in response to a

23

request by defendant EKECHUKWU for a bank account that could receive

24

a fraudulent wire of approximately $500,000, defendant IGBOKWE sent

25

defendant EKECHUKWU the account information for the Wells Fargo 5309

26

Account, including the name of UICC 23, the account number, and the

27

routing number.

28
86

 1

Overt Act No. 419:

On or about July 11, 2017, in response to

2

defendant UCHE’s request for a bank account that could receive an

3

approximately $300,000 BEC fraud payment, defendant IGBOKWE sent

4

defendant UCHE the account information for the Wells Fargo 5309

5

Account and then sent him the account information for a Chase account

6

ending in 7003 of UICC 11 (the “Chase 7003 Account”).

7

Overt Act No. 420:

On or about July 11, 2017, in response to a

8

request by defendant MACWILLIAM CHUKWUOCHA for a bank account that

9

could receive a fraudulent wire of approximately $280,000, defendant

10

IGBOKWE sent defendant MACWILLIAM CHUKWUOCHA the account information

11

for the Wells Fargo 5309 Account, including the name of UICC 23, the

12

account number, and the routing number.

13

Overt Act No. 421:

On or about July 12, 2017, in response to a

14

request by defendant AWAK for a bank account that could receive a

15

fraudulent wire of approximately $500,000, defendant IRO sent

16

defendant AWAK the account information for the BOA 3563 Account,

17

including the account number and the routing number.

18

Overt Act No. 422:

On or about July 12, 2017, defendant EGWUMBA

19

discussed with defendant EROHA how defendant EGWUMBA had been using a

20

computer virus.

21

Overt Act No. 423:

On or about July 12, 2017, defendant IRO

22

told defendant EROHA that for receiving and laundering the proceeds

23

of BEC transactions he would charge a rate of 45%-60% and for romance

24

schemes he could charge 20%-25%, and defendant EROHA provided that

25

information to defendant EGWUMBA.

26
27

Overt Act No. 424:

On or about January 12, 2017, defendant

IGBOKWE sent defendant IHEJIUREME the name of defendant MANSBANGURA

28
87

 1

as the money service account to which defendant IHEJIUREME could

2

direct a fraudulent payment.

3

Overt Act No. 425:

On or about July 13, 2017, defendant IGBOKWE

4

sent defendant ESHIMBU the account information for defendant

5

IGBOKWE’s BOA account ending in 2673 (the “BOA 2673 Account”),

6

including the account number and the routing number, to use in

7

receiving a fraudulent payment.

8

Overt Act No. 426:

On or about July 15, 2017, defendant IGBOKWE

9

sent defendant ODIMARA the account information for a BOA 4560

10

Account, including the account number and the routing number.

11
12

Additional Transfers to Nigerian Bank Accounts
Overt Act No. 427:

On or about February 7, 2017, defendant IRO

13

instructed UICC 3 to transfer approximately 28,800,000 naira from his

14

Nigerian bank account to the Nigerian bank account of defendant

15

OGUNGBE, and noted that those funds were to “buy usd.”

16

Overt Act No. 428:

On or about April 4, 2017, defendant IRO

17

instructed UICC 3 to transfer approximately 3,300,000 naira from his

18

Nigerian bank account to the Nigerian bank account of defendant MBA.

19

Overt Act No. 429:

On or about May 8, 2017, defendant OGUNGBE

20

confirmed to defendant IRO that he had paid approximately 5,000,000

21

naira to the Nigerian bank account of UICC 3 on or about April 16,

22

2017.

23

Overt Act No. 430:

On or about April 19, 2017, defendant IRO

24

instructed defendant IKOGHO to transfer funds from his Nigerian bank

25

account to the Nigerian bank account of UICC 3 and two other Nigerian

26

bank accounts.

27
28
88

 1

Overt Act No. 431:

On or about April 24, 2017, defendant IRO

2

instructed defendant IKOGHO to transfer funds from his Nigerian bank

3

account to the Nigerian bank account of UICC 3.

4

Overt Act No. 432:

On or about April 25, 2017, defendant IRO

5

instructed defendant IKOGHO to transfer approximately 1,250,510 naira

6

from his Nigerian bank account to the Nigerian bank account of UICC

7

3.

8
9

Overt Act No. 433:

On or about April 25, 2017, defendant IRO

instructed defendant IKOGHO to transfer approximately 6,532,000 naira

10

from his Nigerian bank account to the Nigerian bank account of

11

defendant AZUBUIKE.

12

Overt Act No. 434:

On or about April 28, 2017, defendant IRO

13

instructed defendant OGUNGBE to transfer approximately $3,550,000

14

from his Nigerian bank account to the Nigerian bank account of UICC

15

3.

16

Overt Act No. 435:

On or about May 3, 2017, defendant IRO

17

instructed UICC 3 to transfer approximately 5,000,000 naira from his

18

Nigerian bank account to the Nigerian bank account of defendant

19

N. DURU.

20

Overt Act No. 436:

On or about May 8, 2017, defendant IRO

21

instructed defendant IKOGHO to transfer funds from his Nigerian bank

22

account to the Nigerian bank account of defendant N. DURU.

23

Overt Act No. 437:

On or about May 9, 2017, defendant IRO

24

instructed defendant IKOGHO to transfer approximately 26,927,500

25

naira from his Nigerian bank account to the Nigerian bank account of

26

defendant N. DURU.

27
28

Overt Act No. 438:

On or about May 9, 2017, defendant IRO

instructed defendant IKOGHO to transfer approximately 11,791,200
89

 1

naira from his Nigerian bank account to the Nigerian bank account of

2

UICC 3.

3

Overt Act No. 439:

On or about May 9, 2017, defendant IRO

4

instructed defendant IKOGHO to transfer approximately 1,600,000 naira

5

from his Nigerian bank account to the Nigerian bank account of

6

defendant NNAMDI.

7

Overt Act No. 440:

On or about May 9, 2017, defendant IRO

8

instructed defendant IKOGHO to transfer approximately 3,960,000 naira

9

from his Nigerian bank account to the Nigerian bank account of UICC

10

5.

11

Overt Act No. 441:

On or about May 9, 2017, defendant IRO

12

instructed defendant IKOGHO to transfer approximately 4,440,200 naira

13

from his Nigerian bank account to the Nigerian bank account of UICC

14

3.

15

Overt Act No. 442:

On or about May 13, 2017, defendant IRO

16

instructed defendant IKOGHO to transfer approximately 21,300,000

17

naira from his Nigerian bank account to the Nigerian bank account of

18

UICC 5.

19

Overt Act No. 443:

On or about May 15, 2017, defendant IRO

20

instructed UICC 3 to transfer approximately 24,700,000 naira from his

21

Nigerian bank account to the Nigerian bank account of defendant

22

N. DURU.

23

Overt Act No. 444:

On or about May 15, 2017, defendant IRO

24

instructed UICC 3 to transfer approximately 742,500 naira from his

25

Nigerian bank account to the Nigerian bank account of defendant AWAK.

26
27

Overt Act No. 445:

On or about May 15, 2017, defendant IRO

instructed UICC 3 to transfer approximately 200,000 naira from his

28
90

 1

Nigerian bank account to the Nigerian bank account of defendant

2

AZUBUIKE.

3

Overt Act No. 446:

On or about May 7, 2017, defendant OGUNGBE

4

confirmed to defendant IRO that he had paid approximately 5,000,000

5

naira to the Nigerian bank account of UICC 3.

6

Overt Act No. 447:

On or about July 12, 2017, defendants IRO

7

and OGUNGBE discussed a transfer of approximately 2,626,500 to the

8

Nigerian bank account of defendant AJAH.

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
91

 1

COUNT TWO

2

[18 U.S.C. § 1349]

3

[ALL DEFENDANTS]

4

21.

The Grand Jury re-alleges and incorporates paragraphs 1

5

through 16 of the Introductory Allegations of this Indictment here.

6

A.

7

OBJECTS OF THE CONSPIRACY
22.

Beginning on a date unknown to the Grand Jury, but no later

8

than October 7, 2014, and continuing through an unknown date, but no

9

earlier than on or about May 2, 2018, in Los Angeles County, within

10

the Central District of California, and elsewhere, defendants IRO,

11

IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY, MANSBANGURA, AJAEZE,

12

EKECHUKWU, EROHA, OJIMBA, XPLORA G, OCHIAGHA, N. DURU, OFORKA, MARK

13

CHUKWUOCHA, NNAMDI, CHILAKA, OHAJIMKPO, UCHE, ODIONYENMA, OGBONNA,

14

ONWUASOANYA, MACWILLIAM CHUKWUOCHA, UZOKA, AWAK, EGWUMBA, EZIRIM,

15

OKAFOR, SAM MAL, MBA, IKEWESI, OGANDU, ANYANWU, AZUBUIKE, NWACHUKWU,

16

IZUNWANNE, OSUJI, ONYEKA, ANUNOBI, OKOLO, ONUWA, ISAMADE, MADUFOR,

17

NNEBEDUM, OKEREKE, ODIMARA, ONUDOROGU, NZENWAH, OBASI, AGUBE, OKORIE,

18

OHIRI, UGWU, AGWUEGBO, CHUKWU, MEGWA, P. DURU, IWU, CHIKA, MEZIENWA,

19

AGUH, ESHIMBU, ANOZIE, AGUNWA, G. DIKE, UKACHUKWU, OSMUND, NWANGWU,

20

AJAH, EJIOFOR, UBASINEKE, IBETO, NWANEGWO, E. DIKE, EKI, IWUOHA,

21

C. DURU, IHEJIUREME, and MADEKWE, together with UICC 1 through UICC

22

26 and others known and unknown to the Grand Jury, knowingly

23

conspired to commit the following offenses:

24
25

a.

wire fraud, in violation of Title 18, United States

Code, Section 1343;

26

b.

mail fraud, in violation of Title 18, United States

27

Code, Section 1341; and

28
92

 1

c.

2

Code, Section 1344(2).

3

B.

4

bank fraud, in violation of Title 18, United States

THE MANNER AND MEANS OF THE CONSPIRACY
23.

The objects of the conspiracy were to be accomplished, in

5

substance, as follows:

6

a.

Defendants UMEJESI, OGUNGBE, EKECHUKWU, XPLORA G,

7

OCHIAGHA, N. DURU, OFORKA, MARK CHUKWUOCHA, NNAMDI, CHILAKA,

8

OHAJIMKPO, UCHE, ODIONYENMA, OGBONNA, ONWUASOANYA, MACWILLIAM

9

CHUKWUOCHA, UZOKA, AWAK, EGWUMBA, EZIRIM, OKAFOR, SAM MAL, MBA,

10

IKEWESI, OGANDU, ANYANWU, AZUBUIKE, NWACHUKWU, IZUNWANNE, OSUJI,

11

ONYEKA, ANUNOBI, OKOLO, ONUWA, ISAMADE, MADUFOR, NNEBEDUM, OKEREKE,

12

ODIMARA, ONUDOROGU, NZENWAH, OBASI, AGUBE, OKORIE, OHIRI, UGWU,

13

AGWUEGBO, CHUKWU, MEGWA, IWU, CHIKA, MEZIENWA, AGUH, ESHIMBU, ANOZIE,

14

AGUNWA, G. DIKE, UKACHUKWU, OSMUND, NWANGWU, AJAH, EJIOFOR,

15

UBASINEKE, IBETO, NWANEGWO, E. DIKE, EKI, IWUOHA, C. DURU, and

16

IHEJIUREME, or their coconspirators, would identify a potential

17

victim of a BEC fraud, escrow fraud, romance scam, or other

18

fraudulent scheme.

19

i.

As to a potential BEC fraud and escrow fraud

20

victim, this would be done in part by hacking into the email system

21

of either the potential BEC fraud victim or a party with whom the

22

potential BEC fraud victim was communicating, intercepting

23

communications, and directly communicating with the potential victim.

24

ii.

As to a potential romance scam victim, this would

25

be done by employing false and fraudulent personas to virtually meet

26

a potential victim on online dating or social media platforms and

27

attempting to cultivate relationships such that the potential victim

28
93

 1

would incorrectly believe herself or himself to be in a relationship

2

or to be friends with the false and fraudulent persona.

3

b.

The Grand Jury re-alleges and incorporates paragraphs

4

19.a through 19.i of Section B of Count One of this Indictment here.

5

C.

6

OVERT ACTS
24.

In furtherance of the conspiracy, and to accomplish its

7

objects, defendants IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY,

8

MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA, XPLORA G, OCHIAGHA, N.

9

DURU, OFORKA, MARK CHUKWUOCHA, NNAMDI, CHILAKA, OHAJIMKPO, UCHE,

10

ODIONYENMA, OGBONNA, ONWUASOANYA, MACWILLIAM CHUKWUOCHA, UZOKA, AWAK,

11

EGWUMBA, EZIRIM, OKAFOR, SAM MAL, MBA, IKEWESI, OGANDU, ANYANWU,

12

AZUBUIKE, NWACHUKWU, IZUNWANNE, OSUJI, ONYEKA, ANUNOBI, OKOLO, ONUWA,

13

ISAMADE, MADUFOR, NNEBEDUM, OKEREKE, ODIMARA, ONUDOROGU, NZENWAH,

14

OBASI, AGUBE, OKORIE, OHIRI, UGWU, AGWUEGBO, CHUKWU, MEGWA, P. DURU,

15

IWU, CHIKA, MEZIENWA, AGUH, ESHIMBU, ANOZIE, AGUNWA, G. DIKE,

16

UKACHUKWU, OSMUND, NWANGWU, AJAH, EJIOFOR, UBASINEKE, IBETO,

17

NWANEGWO, E. DIKE, EKI, IWUOHA, C. DURU, IHEJIUREME, and MADEKWE,

18

together with other known and unknown to the Grand Jury, on or about

19

the dates set forth below, committed and caused to be committed

20

various overt acts, in the Central District of California and

21

elsewhere, including, but not limited to, the following:

22

Overt Act Nos. 1–447:

The Grand Jury re-alleges and

23

incorporates Overt Act Number 1 through Overt Act Number 447 of

24

Section C of Count One of this Indictment here.

25
26
27
28
94

 1

COUNT THREE

2

[18 U.S.C. § 1349]

3

[DEFENDANTS IRO, ONWUASOANYA, AND IZUNWANNE]

4

25.

The Grand Jury re-alleges and incorporates paragraphs 1 and

5

8 of the Introductory Allegations of this Indictment here.

6

A.

7

OBJECTS OF THE CONSPIRACY
26.

Beginning on a date unknown to the Grand Jury, but no later

8

than September 1, 2014, and continuing through an unknown date, but

9

no earlier than on or about September 11, 2014, in Los Angeles

10

County, within the Central District of California, and elsewhere,

11

defendants IRO, ONWUASOANYA, and IZUNWANNE, together with others

12

known and unknown to the Grand Jury, knowingly conspired to commit

13

wire fraud, in violation of Title 18, United States Code, Section

14

1343.

15

B.

16

THE MANNER AND MEANS OF THE CONSPIRACY
27.

The object of the conspiracy was to be accomplished, in

17

substance, as follows:

18

a.

Defendants ONWUASOANYA, IZUNWANNE, or their

19

coconspirators, would identify a potential victim of BEC fraud.

20

would be done in part by hacking into the email system of either the

21

potential BEC fraud victim or a party with whom the potential BEC

22

fraud victim was communicating, intercepting communications, and

23

directly communicating with the potential victims.

24

b.

Defendants ONWUASOANYA, IZUNWANNE, or their

This

25

coconspirators, would through false and fraudulent pretenses,

26

representations, and promises, and concealment of material facts,

27

persuade a victim to wire funds into a bank account.

28
95

 1

c.

Defendants ONWUASOANYA, IZUNWANNE, IRO, and their

2

coconspirators, would also make false and fraudulent statements,

3

representations, and promises, and conceal material facts, in order

4

to avoid discovery of the fraudulent nature of the deposit, wire, or

5

transfer.

6

d.

Defendants ONWUASOANYA, IZUNWANNE, or their

7

coconspirators would withdraw, and attempt to withdraw, the

8

fraudulently-obtained funds from a bank account before the victim

9

became aware of the fraudulent nature of the transactions, so as to

10

obtain the money and so as to conceal and disguise the nature,

11

location, source, ownership and control of the proceeds.

12

C.

13

OVERT ACTS
Overt Act No. 1:

On or about September 3, 2014, an unknown

14

coconspirator fraudulently induced Victim Company 1 to send a wire

15

transfer of approximately $45,783.97 from its City National Bank

16

account in San Diego County, California, to a fraudulent bank account

17

at HSBC ending in 6100.

18

Overt Act No. 2:

On or about September 11, 2014, prior to

19

Victim Company 1 discovering that it had been defrauded, defendant

20

ONWUASOANYA arranged for defendant IRO to impersonate an employee of

21

Victim Company 1 when speaking to a Chinese representative of Victim

22

Company 1, in order to avoid having the fraudulent scheme be

23

detected.

24

Overt Act No. 3:

On or about September 11, 2014, prior to

25

Victim Company 1 discovering that it had been defrauded, defendant

26

IZUNWANNE provided information to IRO so that defendant IRO could

27

impersonate an employee of Victim Company 1 when speaking to a

28
96

 1

Chinese representative of Victim Company 1, in order to avoid having

2

the fraudulent scheme be detected.

3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
97

 1

COUNTS FOUR THROUGH FORTY-NINE

2

[18 U.S.C. §§ 1343, 2(a)]

3

[DEFENDANTS IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY,

4

MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA, XPLORA G, OCHIAGHA,

5

NNAMDI, CHILAKA, ODIONYENMA, OGBONNA, MACWILLIAM CHUKWUOCHA, UZOKA,

6

AWAK, SAM MAL, AZUBUIKE, ANUNOBI, ONUWA, P. DURU, ANOZIE, AGUNWA, AND

7

NWANGWU]

8
9
10

28.

The Grand Jury re-alleges and incorporates paragraphs 1

through 16 of the Introductory Allegations of this Indictment here.
A.

11

SCHEMES TO DEFRAUD
29.

Beginning on unknown dates no later than on or about

12

September 3, 2015 and continuing through unknown dates no earlier

13

than on or about May 2, 2018, in Los Angeles County, within the

14

Central District of California, and elsewhere, the defendant(s)

15

identified in each Count listed in paragraph 31, together with others

16

known and unknown to the Grand Jury, each aiding and abetting the

17

other, knowingly and with intent to defraud, devised, participated

18

in, and executed and attempted to execute a scheme to defraud a

19

victim as to material matters, and to obtain money and property from

20

such victim by means of material false and fraudulent pretenses,

21

representations, and promises, and the concealment of material facts.

22

30.

The fraudulent schemes were operated and were carried out,

23

in substance, as set forth in paragraph 23 of Count Two of this

24

Indictment.

25

B.

26

USE OF THE WIRES
31.

On or about the following dates, within the Central

27

District of California, and elsewhere, the following defendants, and

28

others known and unknown to the Grand Jury, for the purpose of
98

 1

executing and attempting to execute the above-described schemes to

2

defraud, transmitted and caused the transmission of the following

3

items by means of wire communication in interstate and foreign

4

commerce:

5
COUNT

DEFENDANT(S)

DATE

ITEM WIRED

6
Scheme as to Victim M.S.

7
8

IRO and
OGBONNA

9/3/2015

IRO and
OGBONNA

9/8/2015

IRO and
OGBONNA

9/10/2015

IRO and
OGBONNA

9/14/2015

9
10
11
12
13
14
15
16
17
18
19
20

Wire transfer of approximately
$23,000 from the BOA account of
M.S., held in Monterey Park,
California, through interstate
wires, to Chase checking account
ending in 9837 of defendant IRO,
doing business as (“dba”) “VOI
Enterprises,” held in Carson,
California (the “Chase 9837
Account”)
Wire transfer of approximately
$46,500 from the BOA account of
M.S., held in Monterey Park,
California, through interstate
wires, to the Chase 9837 Account
Wire transfer of approximately
$4,700 from the BOA account of
M.S., held in Monterey Park,
California, through interstate
wires, to the Chase 9837 Account
Wire transfer of approximately
$17,000 from the BOA account of
M.S., held in Monterey Park,
California, through interstate
wires, to the Chase 9837 Account

Scheme as to Victim Company 2
21
22
23

IRO

2/12/2016

Wire transfer of approximately
$186,686 from the United Bank of
Africa account of Victim Company
2, through interstate wires, to
the Chase 9837 Account

24
25
26
27
28
99

 1
2
3

Scheme as to Victim R.B.
IRO,
ODIONYENMA,
and AWAK

3/31/2016

IRO,
ODIONYENMA,
and AWAK

4/4/2016

IRO,
ODIONYENMA,
and AWAK

4/7/2016

4
5
6
7
8
9
10
11
12
13
14

Scheme as to Victim F.K.
IGBOKWE,
MANSBANGURA,
and ANUNOBI

5/30/2016

IGBOKWE,
MANSBANGURA,
and ANUNOBI

7/13/2016

15
16
17

IGBOKWE and
MANSBANGURA

10/26/2016

20
21
22
23
24
25

Wire transfer of approximately
$6,824 from a bank account in
Japan to a Chase account ending
in 1577 of UICC 2, held in Los
Angeles, California
Wire transfer of approximately
$33,128.26 from a bank account
in Japan to a Chase account
ending in 0655 of UICC 1

Scheme as to Victim J.G.

18
19

Wire transfer of approximately
$18,000 from a Wells Fargo
account of R.B., held in Panama
City Beach, Florida, to a bank
account at Comerica ending in
2663 of defendant IRO, dba “IRVA
Auto Sales & Equip Broker LLC,”
held in Carson, California
(“Comerica 2663 Account”)
Wire transfer of approximately
$39,000 from a Wells Fargo
account of R.B., held in Panama
City Beach, Florida, to the
Comerica 2663 Account
Wire transfer of approximately
$30,000 from a Wells Fargo
account of R.B., held in Panama
City Beach, Florida, to a Wells
Fargo account ending in 7410

Wire transfer of approximately
$30,000 from a Heritage Bank of
Nevada account to a US Bank
account ending in 2669 of UICC
1, held in Los Angeles,
California

Scheme as to Victim Company 3
IGBOKWE and
MANSBANGURA

12/19/2016

Wire transfer of approximately
$18,457.13 from Chase account of
Victim Company 3, held in
Oklahoma, to a US Bank account
ending in 2982 of UICC 2, held
in Los Angeles, California

26
27
28
100

 1
2
3

Scheme as to Victim B.Z.
IGBOKWE,
MANSBANGURA,
and ONUWA

3/16/2017

4
5
6
7
8

Scheme as to Victim Company 4
IGBOKWE,
UMEJESI, and
OJIMBA

3/29/2017

9
10
IGBOKWE,
CHILAKA, and
MANSBANGURA

4/11/2017

IGBOKWE,
CHILAKA, and
MANSBANGURA

4/27/2017

IGBOKWE,
CHILAKA, and
MANSBANGURA

5/1/2017

13
14
15
16
17
18
19
20

Wire transfer of approximately
$29,679.17 from a Banco Bilbao
Vizcaya Argentaria, S.A. account
of Victim Company 4, held in
Colombia, to a Wells Fargo
account ending in 7245 of UICC
9, held in Whittier, California

Scheme as to Victim A.V.

11
12

Wire transfer of approximately
$11,900 from a Chemical Bank
account of B.Z., held in
Michigan, to a Chase account
ending in 7605 of UICC 1, in Los
Angeles, California (the “Chase
7605 Account”)

21

Wire transfer of approximately
$8,035 from a Capital One
account of A.V., held in
Maryland, to a Wells Fargo
account ending in 1147 of UICC
24, in Los Angeles, California
Wire transfer of approximately
$2,700 from a Capital One
account of A.V., held in
Maryland, to a Chase account
ending in 5027 of UICC 1, which
account was held in Los Angeles,
California (the “Chase 5027
Account”)
Wire transfer of approximately
$3,360 from a Capital One
account of A.V., held in
Maryland, to the Chase 5027
Account

Scheme as to Victims Je.F. and Jo.F.
22
23
24
25

IRO,
EKECHUKWU,
AZUBUIKE,
and ANOZIE

4/17/2017

Wire transfer of approximately
$135,800 from a BMO Harris Bank
account of Je.F. and Jo.F., held
in Illinois, to a Chase account
ending in 6217 of UICC 24, held
in Hawthorne, California

26
27
28
101

 1
2
3

Scheme as to Victim Company 6
IRO, CATHEY,
and NNAMDI

4/10/2017

4
5
6

Message from defendant NNAMDI
requesting that defendant IRO
open a bank account in the name
of a Chinese company (“Chinese
Company 1”), related to an
approximately $900,000 wire
transfer to be fraudulentlyobtained from Victim Company 6

Scheme as to Victim Company 7
7
8

IRO and
ANOZIE

4/21/2017

9
10

Scheme as to Victim D.J.

11
12
13

Wire transfer of approximately
$23,789 from a BOA account of
Victim Company 7, held in North
Carolina, to a Chase checking
account ending in 7866 of UICC
25, held in Carson, California

IGBOKWE,
ODIONYENMA,
MANSBANGURA,
and P. DURU

5/5/2017

14
15

Photo of a deposit receipt sent
by defendant ODIONYENMA to
defendant IGBOKWE, from the
deposit of a money order of
approximately $25,600 from a
Wells Fargo branch in Minnesota,
by D.J., into a Wells Fargo
account ending in 4899 of
defendant P. DURU

16
Scheme as to Victim L.B.
17
18

IRO, AWAK,
and IGBOKWE

5/9/2017

19
20
21
22
23
24
25

Wire transfer of approximately
$3,000 from a Wells Fargo
account of L.B., held in
Alabama, to a BOA account ending
in 2660 of defendant IGBOKWE,
held in Los Angeles, California

Scheme as to Victim Company 9
IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA

5/10/2017

Wire transfer of approximately
$220,462.68 from a First
Caribbean International Bank
account of Victim Company 9,
held in St. Vincent, to a BOA
account ending in 1004 of UICC
11, held in Northridge,
California

26
27
28
102

 1
2
3
4

Scheme as to Victim Law Firm
IRO,
IGBOKWE,
CATHEY, and
OCHIAGHA

5/11/2017

5

Wire transfer of approximately
$83,140.98 from a SunTrust
account of the Victim Law Firm,
held in North Carolina, to a
Chase account ending in 5899,
held in Los Angeles, California

Scheme as to Victim D.V.
6
7

IGBOKWE and
MANSBANGURA

5/13/2017

IGBOKWE and
MANSBANGURA

5/15/2017

8
9
10
11
12
13

Payment of approximately $500 by
D.V. via Western Union to the
account of UICC 1, in Los
Angeles, California
Payment of approximately $500 by
D.V. via Western Union to the
account of UICC 1, in Los
Angeles, California

Scheme as to Victim Company 10
IRO,
IGBOKWE,
CATHEY, and
OCHIAGHA

5/17/2017

14
15

Wire transfer of approximately
$301,201.20 from a China
Merchants Bank account of Victim
Company 10, held in China, to a
Chase account ending in 7262 of
UICC 12, held in Inglewood,
California

Scheme as to Victim T.P.
16
17

IRO, CATHEY,
NNAMDI, and
OGUNGBE

6/5/2017

18
19
20
21
22

Scheme as to Victim Company 11
IRO, IKOGHO,
UMEJESI,
CATHEY,
EROHA, and
XPLORA G

6/13/2017

IRO, IKOGHO,
UMEJESI,
CATHEY,
EROHA, and
XPLORA G

6/22/2017

23
24
25
26
27

Wire transfer of approximately
$64,554 from a HSBC bank account
used by T.P., held in Hong Kong,
to a Chase account ending in
7522, held in Los Angeles,
California

Wire transfer of approximately
$297,617.11 from an Arab Bank
PLC account of Victim Company
11, held in Lebanon, to a BOA
account ending in 4180, of UICC
12, held in Inglewood,
California
Wire transfer of approximately
$297,617.11 from an Arab Bank
PLC account of Victim Company
11, held in Lebanon, to a Wells
Fargo account ending in 7984 of
UICC 13, held in Inglewood,
California

28
103

 1
2
3
4
5

Scheme as to Victim B.P.
IGBOKWE,
MANSBANGURA,
and AGUNWA

6/23/2017

IGBOKWE,
MANSBANGURA,
and AGUNWA

6/27/2017

IGBOKWE,
MANSBANGURA,
and AGUNWA

7/13/2017

6
7
8
9

Wire transfer of approximately
$750 from a First Hawaiian Bank
account of B.P., held in Hawaii,
to the Chase 7605 Account
Wire transfer of approximately
$1,500 from a First Hawaiian
Bank account of B.P., held in
Hawaii, to the Chase 7605
Account
Wire transfer of approximately
$2,550 from a First Hawaiian
Bank account of B.P., held in
Hawaii, to the Chase 7605
Account

Scheme as to Victim Solicitor Firm
10
11
12

IRO,
IGBOKWE,
IKOGHO,
CATHEY, and
OCHIAGHA

6/22/2017

13
14
15
16

Scheme as to Victim Company 12
IRO, CATHEY,
and
XPLORA G

5/30/2017

17
18
19
20

IGBOKWE,
MANSBANGURA,
and NWANGWU

6/16/2017

IRO,
IGBOKWE,
EROHA, and
MACWILLIAM
CHUKWUOCHA

7/6/2017

IRO,
IGBOKWE,
EROHA, and
MACWILLIAM
CHUKWUOCHA

7/17/2017

25
26
27
28

Wire transfer of approximately
$500 from a Capital City Bank
account of a Kansas company,
held in Kansas, to the Chase
5027 Account

Scheme as to Victim M.G.

22

24

Account information, including
the account number and routing
number, for a Chase account
ending in 6679 sent by defendant
IRO to defendant XPLORA G

Scheme as to Victim D.A.

21

23

Wire transfer of approximately
$199,960 from a Lloyds Bank
account of Victim Solicitor
Firm, held in the United
Kingdom, to a Chase account
ending in 7633 of UICC 14, held
in Culver City, California

Wire transfer of approximately
$11,000 from an HSBC account of
M.G., held in Mexico, to a BOA
account ending in 3563 of
defendant EROHA, held in
Inglewood, California (the “BOA
3563 Account”)
Wire transfer of approximately
$5,000 from an HSBC account of
M.G., held in Mexico, to the BOA
3563 Account
104

 1
2
3

IRO,
IGBOKWE,
AJAEZE, and
MACWILLIAM
CHUKWUOCHA

12/15/2017

IRO,
IGBOKWE,
AJAEZE, and
MACWILLIAM
CHUKWUOCHA
IRO,
IGBOKWE,
AJAEZE, and
MACWILLIAM
CHUKWUOCHA

12/22/2017

4
5
6
7
8
9

5/2/2018

Wire transfer of approximately
$5,500 from an HSBC account of
M.G., held in Mexico, to a BOA
account ending in 3349 of
defendant AJAEZE in Harbor City,
California (the “BOA 3349
Account”)
Wire transfer of approximately
$2,000 from an HSBC account of
M.G., held in Mexico, to the BOA
3349 Account
Wire transfer of approximately
$11,000 from an HSBC account of
M.G., held in Mexico, to a US
Bank account ending in 2910 of
defendant AJAEZE, held in
Inglewood, California

10
Scheme as to Victim Company 13
11
12
13
14

IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL

8/3/2017

15

Scheme as to Victim Company 14

16
17

IRO and
AJAEZE

1/18/2018

IRO and
AJAEZE

1/30/2018

18
19
20
21
22
23
24
25
26

Wire transfer of approximately
$382,295 from an Abu Dhabi
Commercial Bank of Victim
Company 13, held in Dubai, to a
Chase account ending in 5092 of
UICC 16, held in Hawthorne,
California (the “Chase 5092
Account”)

Wire transfer of approximately
$76,688.99 from Commerzbank AG
account of Victim Company 14,
held in Germany, to a Chase
account ending in 0038 of
defendant AJAEZE, held in
Carson, California (the “Chase
0038 Account”)
Wire transfer of approximately
$39,004.47 from Commerzbank AG
account of Victim Company 14,
held in Germany, to the Chase
0038 Account

Scheme as to Victim Company 15
IRO, IKOGHO,
and AJAEZE

2/14/2018

Wire transfer of approximately
$886,950 from a PT Bank Mandiri
Tbk account, held in Indonesia,
to the Chase 0038 Account

27
28
105

 1
2
3
4
5

Scheme as to Victim Company 16
IRO and
AJAEZE

2/15/2018

Wire transfer of approximately
$1,750,000 from a National
Westminster Bank PLC account,
held in the United Kingdom, to a
Wells Fargo account ending in
1849 of defendant AJAEZE, held
in Carson, California

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
106

 1

COUNTS FIFTY AND FIFTY-ONE

2

[18 U.S.C. §§ 1344(2); 2(a)]

3

[DEFENDANTS IRO, IGBOKWE, AND MANSBANGURA]

4

32.

The Grand Jury re-alleges and incorporates paragraphs 1, 2,

5

and 13 of the Introductory Allegations of this Indictment here.

6

A.

7

THE SCHEME TO DEFRAUD
33.

Beginning on an unknown date, but no later than on or about

8

February 17, 2017, and continuing through on or about June 21, 2017,

9

in Los Angeles County, within the Central District of California, and

10

elsewhere, defendants IRO, IGBOKWE, and MANSBANGURA, together with

11

others known and unknown to the Grand Jury, each aiding and abetting

12

the other, knowingly and with intent to defraud, executed, and

13

attempted to execute a scheme to obtain moneys, funds, credits,

14

assets, and other property owned by and under the custody and control

15

of Wells Fargo by means of material false and fraudulent pretenses,

16

representations, and promises, and the concealment of material facts.

17
18

34.

The fraudulent scheme operated, in substance, in the

following manner:

19

a.

Defendant IRO would instruct defendant IGBOKWE to have

20

defendant MANSBANGURA and UICC 1 open a bank account in the name of

21

Victim Company 5.

22

b.

Defendant IGBOKWE would relay to defendant MANSBANGURA

23

defendant IRO’s request to open a bank account in the name of Victim

24

Company 5.

25

c.

Defendant MANSBANGURA would cause to be filed with the

26

Los Angeles County Registrar-Recorder/County Clerk’s Office a

27

Fictitious Business Name Statement similar to the name of Victim

28

Company 5.
107

 1

d.

Defendant MANSBANGURA would cause to be opened a bank

2

account in the name of UICC 1, with the business name of the bank

3

account similar to that of Victim Company 5.

4

e.

Defendant MANSBANGURA would provide the bank account

5

information, including the name of UICC 1, the account number, and

6

the routing number, to defendant IGBOKWE who, in turn, would provide

7

it to defendant IRO.

8

f.

Unknown coconspirators would send or cause to be sent

9

to Wells Fargo a forged and fraudulent request purporting to be from

10

Victim Company 5, requesting that Wells Fargo close the bank account

11

of Victim Company 5 held at Wells Fargo and transfer the balance of

12

the account to the bank account opened in the name of UICC 1.

13

B.

14

EXECUTION OF THE FRAUDULENT SCHEME
35.

On or about the following dates, in Los Angeles County,

15

within the Central District of California, and elsewhere, defendants

16

IRO, IGBOKWE, and MANSBANGURA, together with others known and unknown

17

to the Grand Jury, each aiding and abetting the other, committed the

18

following acts, each of which constituted an execution of the

19

fraudulent scheme:

20
COUNT

DATE

ACT

3/29/17

An unknown coconspirator caused to be sent to
Wells Fargo a forged and fraudulent request
purporting to be from Victim Company 5, requesting
that Victim Company 5’s account at Wells Fargo be
closed and that the balance, which was
approximately $17,300,844.58 at the time, be
transferred to a Chase account ending in 5027 of
UICC 1, which defendants IRO, IGBOKWE, and
MANSBANGURA caused to be opened and which account
was held in Los Angeles, California (the “Chase
5027 Account”)

21
22
23
24
25
26
27
28
108

 1
2
3
4
5

6/3/2017 An unknown coconspirator caused to be sent to
Wells Fargo a forged and fraudulent request
purporting to be from Victim Company 5, requesting
that Victim Company 5’s account at Wells Fargo be
closed and that the balance, which was
approximately $12,760,922.93 at the time, be
transferred to the Chase 5027 Account, which
defendants IRO, IGBOKWE, and MANSBANGURA caused to
be opened

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
109

 1

COUNTS FIFTY-TWO THROUGH ONE HUNDRED TWENTY-THREE

2

[18 U.S.C. §§ 1956(a)(1)(B)(i); 2(a)]

3

[DEFENDANTS IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY,

4

MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA, OCHIAGHA, OGBONNA,

5

MACWILLIAM CHUKWUOCHA, UZOKA, AWAK, SAM MAL, ONUWA, AND ANOZIE]

6
7
8
9

36.

The Grand Jury re-alleges and incorporates paragraphs 1

through 16 of the Introductory Allegations of this Indictment here.
37.

On or about the following dates, in Los Angeles County,

within the Central District of California, and elsewhere, the

10

following defendants and others known and unknown to the Grand Jury,

11

each aiding and abetting the other, conducted and attempted to

12

conduct the financial transactions described below affecting

13

interstate and foreign commerce, knowing that the property involved

14

represented the proceeds of some form of unlawful activity, and which

15

transactions, in fact, involved the proceeds of specified unlawful

16

activity, namely, wire fraud, in violation of Title 18, United States

17

Code, Section 1343; and mail fraud, in violation of Title 18, United

18

States Code, Section 1341; and bank fraud, in violation of Title 18,

19

United States Code, Section 1344(2), and knowing that each of the

20

transactions was designed in whole and in part to conceal and

21

disguise the nature, location, source, ownership, and control of such

22

proceeds:

23
COUNT

DEFENDANT(S)

DATE

TRANSACTION

IRO and
OGBONNA

9/4/2015

IRO and
OGBONNA

9/8/2015

Withdrawal of approximately $14,000
from the Chase checking account
ending in 9837 of defendant IRO,
doing business as (“dba”) “VOI
Enterprises,” held in Carson,
California (the “Chase 9837
Account”)
Withdrawal of approximately $8,000
from the Chase 9837 Account
110

24
25
26
27
28

 1
2
3
4
5
6

IRO and
OGBONNA
IRO and
OGBONNA
IRO and
OGBONNA
IRO and
OGBONNA
IRO and
OGBONNA
IRO

9/10/2015

IRO

2/12/2016

IRO

2/16/2016

IRO

2/16/2016

IRO

2/16/2016

IRO

2/16/2016

IRO

2/16/2016

IRO

2/18/2016

IGBOKWE and
MANSBANGURA

10/28/2016

IGBOKWE and
MANSBANGURA

10/28/2016

9/10/2015
9/17/2015
9/17/2015
9/17/2015
2/12/2016

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Withdrawal of approximately $30,000
from the Chase 9837 Account
Withdrawal of approximately $9,000
from the Chase 9837 Account
Withdrawal of approximately $10,000
from the Chase 9837 Account
Withdrawal of approximately $20,000
from the Chase 9837 Account
Withdrawal of approximately $5,000
from the Chase 9837 Account
Transfer of approximately $188,600
from the Chase 9837 Account to a
Chase savings account ending in
0820 of defendant IRO, dba VOI
Enterprises, held in Carson,
California (“Chase 0820 Account”)
Transfer of approximately $161,700
from the Chase 0820 Account to the
Chase 9837 Account
Wire transfer of approximately
$132,950 from the Chase 9837
Account to a Wells Fargo account
ending in 6061 of defendant IRO,
dba “Irva Auto Sales & Equip Broker
LLC,” held in Carson, California
(“Wells Fargo 6061 Account”)
Wire transfer of approximately
$28,670 from the Chase 9837 Account
to the bank account ending in 3107
of UICC 7 at CalCom FCU, held in
Torrance, California (“CalCom 3107
Account”)
Wire transfer of approximately
$27,500 from the CalCom 3107
Account to the Wells Fargo 6061
Account
Wire transfer of approximately
$50,000 from the Wells Fargo 6061
Account to a BOA account ending in
1824
Withdrawal of approximately $50,000
from the Wells Fargo 6061 Account
Wire transfer of approximately
$30,500 from the Wells Fargo 6061
Account to a Chase account ending
in 1279 of UICC 8
Withdrawal of approximately $5,500
from a US Bank account ending in
2669 of UICC 1, held in Los
Angeles, California (the “US Bank
2669 Account”), through check
addressed to defendant MANSBANGURA
Withdrawal of approximately $8,845
from the US Bank 2669 Account,
through check addressed to UICC 2
111

 1

IGBOKWE and
MANSBANGURA

10/31/2016

IGBOKWE and
MANSBANGURA

11/1/2016

IGBOKWE and
MANSBANGURA

12/20/2016

IGBOKWE,
MANSBANGURA,
and ONUWA

3/16/2017

IGBOKWE,
UMEJESI, and
OJIMBA

3/31/2017

IGBOKWE,
UMEJESI, and
OJIMBA

3/31/2017

IRO and
ANOZIE

4/21/2017

IRO and
ANOZIE

4/24/2017

IRO and
ANOZIE
IRO and
ANOZIE

4/24/2017

IRO, IGBOKWE
and AWAK

6/7/2017

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

4/25/2017

24
25
26
27
28

Withdrawal of approximately $7,580
from the US Bank 2669 Account,
through check addressed to UICC 2
Withdrawal of approximately $7,500
from the US Bank 2669 Account,
through check addressed to
defendant MANSBANGURA
Withdrawal of approximately $8,500
from a US Bank account ending in
2982 of UICC 2, held in Los
Angeles, California (“US Bank 2982
Account”)
Withdrawal of approximately $4,000
from a Chase account ending in 7605
of UICC 1, in Los Angeles,
California (the “Chase 7605
Account”), through a check for
“Rent”
Withdrawal of approximately $11,160
from a Wells Fargo account ending
in 7245 of UICC 9, held in
Whittier, California (the “Wells
Fargo 7245 Account”), through a
check addressed to defendant
UMEJESI
Withdrawal of approximately $16,520
from the Wells Fargo 7245 Account,
through a check addressed to
defendant OJIMBA
Transfer of approximately $2,700
from a Chase checking account
ending in 7866 of UICC 25, held in
Carson, California (the “Chase 7866
Account”) to a Chase savings
account ending in 9927 of UICC 25,
held in Carson, California (the
“Chase 9927 Account”)
Wire transfer of approximately
$18,598 from the Chase 7866 Account
to a SunTrust account of “B&B
Motors of Tampa Bay Inc.”
Withdrawal of approximately $500
from the Chase 7866 Account
Wire transfer of approximately
$1,450 from the Chase 7866 Account
to a U.S. Bank account ending in
0953
Payment of approximately $1,225
from a BOA account ending in 2660
of defendant IGBOKWE, held in Los
Angeles, California (the “BOA 2660
Account”) to U.S. Citizenship and
Immigration services for defendant
IGBOKWE’s application for lawful
permanent residence
112

 1
2
3

IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA

5/11/2017

IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA
IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA
IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA
IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA
IGBOKWE and
MANSBANGURA

5/12/2017

IGBOKWE and
MANSBANGURA

5/15/2017

IRO,
OGUNGBE,
CATHEY, and
NNAMDI

6/6/2017

IRO,
OGUNGBE,
CATHEY, and
NNAMDI
IRO,
OGUNGBE,
CATHEY, and
NNAMDI

6/7/2017

4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26

Wire transfer of approximately
$60,000 from a BOA account ending
in 1004 of UICC 11, held in
Northridge, California (the “BOA
1004 Account”) to a BOA account
ending in 5283, held in Paramount,
California (the “BOA 5283 Account”)
Wire transfer of approximately
$75,500 from the BOA 1004 Account
to a BOA account ending in 9405,
held in Bellingham, Massachusetts
(the “BOA 9405 Account”)

5/15/2017

Withdrawal of a cashier’s check of
approximately $21,000, addressed to
defendant UMEJESI, from the BOA
1004 Account

5/15/2017

Purchase of a cashier’s check of
approximately $9,500, addressed to
defendant IGBOKWE, from the BOA
1004 Account

5/15/2017

Wire transfer of approximately
$30,000 from the BOA 1004 Account
to the BOA 9405 Account

5/15/2017

Withdrawal of approximately $500
from the Western Union account of
UICC 1, in Los Angeles, California
Withdrawal of approximately $500
from the Western Union account of
UICC 1, in Los Angeles, California
Withdrawal of approximately $8,500
from a Chase account ending in
7522, held in Los Angeles,
California (the “Chase 7522
Account”)
Withdrawal of approximately $7,100
from the Chase 7522 Account

6/7/2017

Wire transfer of approximately
$47,000 from the Chase 7522 Account
to a Citibank account of a Hong
Kong company

27
28
113

 1
2
3

IRO,
IGBOKWE,
IKOGHO,
CATHEY, and
OCHIAGHA

6/23/2017

IRO,
IGBOKWE,
IKOGHO,
CATHEY, and
OCHIAGHA
IRO,
IGBOKWE,
AJAEZE,
EROHA, and
MACWILLIAM
CHUKWUOCHA

6/26/2017

IRO,
IGBOKWE,
AJAEZE,
EROHA, and
MACWILLIAM
CHUKWUOCHA
IRO,
IGBOKWE,
AJAEZE,
EROHA, and
MACWILLIAM
CHUKWUOCHA
IRO,
IGBOKWE,
AJAEZE,
EROHA, and
MACWILLIAM
CHUKWUOCHA
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL

7/11/2017

4
5
6
7
8
9
10

7/10/2017

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Withdrawal of approximately $43,750
from a Chase account ending in 7633
of UICC 14, held in Culver City,
California (“Chase 7633 Account”),
through check deposited to a Chase
account ending in 6781 of UICC 15
in Los Angeles, California (“Chase
6781 Account”)
Withdrawal of approximately $9,150
from the Chase 7633 Account through
a cashier’s check
Wire transfer of approximately
$6,000 from a BOA account ending in
3563 of defendant EROHA, held in
Inglewood, California (the “BOA
3563 Account”) to a Wells Fargo
account ending in 5736 of defendant
MACWILLIAM CHUKWUOCHA, held in
Orlando, Florida (the “Wells Fargo
5736 Account”)
Wire transfer of approximately
$2,800 from the BOA 3563 Account to
the Wells Fargo 5736 Account

7/17/2017

Withdrawal of approximately $5,000
from the BOA 3563 Account

7/17/2017

Deposit of approximately $4,150 to
the Wells Fargo 5736 Account

8/5/2017

Withdrawal of approximately
$47,606.40 from a Chase account
ending in 5092 of UICC 16, held in
Hawthorne, California (the “Chase
5092 Account”) through a cashier’s
check

8/5/2017

Withdrawal of approximately $52,602
from the Chase 5092 Account through
a cashier’s check

114

 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL

8/7/2017

Withdrawal of approximately $65,965
from the Chase 5092 Account through
a cashier’s check

8/8/2017

Withdrawal of approximately $35,000
from the Chase 5092 Account through
a cashier’s check

8/9/2017

Withdrawal of approximately $35,000
from the Chase 5092 Account through
a cashier’s check

8/10/2017

Withdrawal of approximately $35,000
from the Chase 5092 Account through
a cashier’s check

8/10/2017

Wire transfer of approximately
$60,000 from the Chase 5092 Account
to the BOA 2660 Account

8/15/2017

Wire transfer of approximately
$54,600 from the BOA 2660 Account
to a Chase account ending in 9931
of OGUNGBE, dba “P and P Motors
LLC,” held in Santa Fe Springs,
California.

8/15/2017

Deposit of a cashier’s check of
approximately $35,000, issued from
Chase 5092 Account, into a Chase
account ending in 5812 of UICC 16,
held in Inglewood, California
(“Chase 5812 Account”)

26
27
28
115

 1
2
3
4
5

IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO and
AJAEZE

8/22/2017

Deposit of a cashier’s check of
approximately $35,000, issued from
the Chase 5092 Account, into the
Chase 5812 Account

1/19/2018

IRO and
AJAEZE

1/19/2018

IRO and
AJAEZE

1/22/2018

IRO and
AJAEZE

1/23/2018

IRO and
AJAEZE

1/30/2018

IRO and
AJAEZE

1/31/2018

IRO and
AJAEZE

2/1/2018

IRO and
AJAEZE

2/5/2018

IRO and
AJAEZE

2/5/2018

IRO, IKOGHO,
and AJAEZE

2/15/2018

IRO, IKOGHO,
and AJAEZE

2/16/2018

IRO, IKOGHO,
and AJAEZE

2/16/2018

Wire transfer of approximately
$27,455 from a Chase account ending
in 0038 of defendant AJAEZE, held
in Carson, California (the “Chase
0038 Account”), to a Wells Fargo
account in the name “Cadon Auto
Corporation”
Wire transfer of approximately
$51,865 from the Chase 0038 Account
to a Mashreqbank PSC account, held
in the United Arab Emirates, in the
name “Elite Auto Fze”
Withdrawal of approximately $500
from the Chase 0038 Account from an
ATM in Los Angeles, California
Withdrawal of approximately $500
from the Chase 0038 Account from an
ATM in Carson, California
Withdrawal of approximately $500
from the Chase 0038 Account from an
ATM in Los Angeles, California
Wire transfer of approximately
$19,000 from the Chase 0038 Account
to a PNC Bank account of The George
Washington University to pay the
Spring 2018 tuition of a student
Purchase of a cashier’s check of
approximately $12,793 from the
Chase 0038 Account
Withdrawal of approximately $2,000
from the Chase 0038 Account from a
Chase bank branch in Carson,
California
Withdrawal of approximately $500
from the Chase 0038 Account from an
ATM in Carson, California
Wire transfer of approximately
$84,985 from the Chase 0038 Account
to a BOA account ending in 5903
Wire transfer of approximately
$189,000 from the Chase 0038
Account to a Compass Bank account
ending in 3681 of defendant IKOGHO,
held in Lynwood, California (the
“Compass Bank 3681 Account”)
Check of approximately $8,000
negotiated from the Compass Bank
3681 Account
116

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

 1

IRO, IKOGHO,
and AJAEZE

2/16/2018

IRO, IKOGHO,
and AJAEZE

2/16/2018

IRO, IKOGHO,
and AJAEZE

2/17/2018

IRO and
AJAEZE

2/16/2018

IRO and
AJAEZE

2/16/2018

IRO and
AJAEZE

2/16/2018

2
3
4
5
6
7
8
9
10
11
12
13
14

Purchase of cashier’s check of
approximately $35,000 from the
Compass Bank 3681 Account
Withdrawal of approximately $8,000
from the Chase 0038 Account from a
Chase bank branch in Carson,
California
Withdrawal of approximately $500
from the Chase 0038 Account from an
ATM in Los Angeles, California
Wire transfer of approximately
$200,000 from a Wells Fargo account
ending in 1849 of defendant AJAEZE,
held in Carson, California (the
“Wells Fargo 1849 Account”) to a
Wells Fargo account ending in 7748
of defendant AJAEZE, held in
Westchester, California (the “Wells
Fargo 7748 Account”)
Wire transfer of approximately
$500,000 from the Wells Fargo 1849
Account to the Wells Fargo 7748
Account
Wire transfer of approximately
$500,000 from the Wells Fargo 1849
Account to the Wells Fargo 7748
Account

15
16
17
18
19
20
21
22
23
24
25
26
27
28
117

 1

COUNTS ONE HUNDRED TWENTY-FOUR THROUGH ONE HUNDRED SIXTY

2

[18 U.S.C. §§ 1957; 2(a)]

3

[DEFENDANTS IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY, AJAEZE,

4

EKECHUKWU, OCHIAGHA, OGBONNA, UZOKA, SAM MAL, AND ANOZIE]

5
6
7

38.

The Grand Jury re-alleges and incorporates paragraphs 1

through 16 of the Introductory Allegations of this Indictment here.
39.

On or about the following dates, in Los Angeles County,

8

within the Central District of California, and elsewhere, the

9

following defendants and others known and unknown to the Grand Jury,

10

each aiding and abetting the other, knowingly engaged in, attempted

11

to engage in, and caused others to engage in and attempt to engage in

12

the following monetary transactions, in and affecting interstate and

13

foreign commerce, in criminally derived property of a value greater

14

than $10,000, by making the following transfers, such property having

15

been derived from specified unlawful activity, namely, wire fraud, in

16

violation of Title 18, United States Code, Section 1343, and bank

17

fraud, in violation of Title 18, United States Code, Section 1344(2),

18

knowing that the funds involved represented the proceeds of some form

19

of unlawful activity:

20
COUNT

DEFENDANT(S)

DATE

TRANSACTION

IRO and
OGBONNA

9/4/2015

IRO and
OGBONNA

9/10/2015

Withdrawal of approximately $14,000
from the Chase checking account
ending in 9837 of defendant IRO,
doing business as (“dba”) “VOI
Enterprises,” held in Carson,
California (the “Chase 9837
Account”)
Withdrawal of approximately $30,000
from the Chase 9837 Account

21
22
23
24
25
26
27
28
118

 1

IRO

2/12/2016

IRO

2/12/2016

IRO

2/16/2016

IRO

2/16/2016

IRO

2/16/2016

IRO

2/16/2016

16

IRO

2/16/2016

17

IRO

2/18/2016

IRO and
ANOZIE

4/24/2017

IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA

5/11/2017

IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA

5/12/2017

2
3
4
5
6
7
8
9
10
11
12
13
14
15

18
19
20
21
22
23
24
25
26
27

Transfer of approximately $188,600
from the Chase 9837 Account to a
Chase savings account ending in
0820 of defendant IRO, dba VOI
Enterprises, held in Carson,
California (“Chase 0820 Account”)
Transfer of approximately $161,700
from the Chase 0820 Account to the
Chase 9837 Account
Wire transfer of approximately
$132,950 from the Chase 9837
Account to a Wells Fargo account
ending in 6061 of defendant IRO,
dba “Irva Auto Sales & Equip Broker
LLC,” held in Carson, California
(“Wells Fargo 6061 Account”)
Wire transfer of approximately
$28,670 from the Chase 9837 Account
to the bank account ending in 3107
of UICC 7 at CalCom FCU, held in
Torrance, California (“CalCom 3107
Account”)
Wire transfer of approximately
$27,500 from the CalCom 3107
Account to the Wells Fargo 6061
Account
Wire transfer of approximately
$50,000 from the Wells Fargo 6061
Account to a BOA account ending in
1824
Withdrawal of approximately $50,000
from the Wells Fargo 6061 Account
Wire transfer of approximately
$30,500 from the Wells Fargo 6061
Account to a Chase account ending
in 1279 of UICC 8
Wire transfer of approximately
$18,598 from the Chase 7866 Account
to a SunTrust account of B&B Motors
of Tampa Bay Inc.
Wire transfer of approximately
$60,000 from a BOA account ending
in 1004 of UICC 11, held in
Northridge, California (the “BOA
1004 Account”) to a BOA account
ending in 5283, held in Paramount,
California
Wire transfer of approximately
$75,500 from the BOA 1004 Account
to a BOA account ending in 9405,
held in Bellingham, Massachusetts
(the “BOA 9405 Account”)

28
119

 1
2
3
4
5
6
7
8

IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA
IRO,
IGBOKWE,
IKOGHO,
UMEJESI,
OGUNGBE, and
UZOKA
IRO,
OGUNGBE,
CATHEY, and
NNAMDI

5/15/2017

Withdrawal of cashier’s check of
approximately $21,000, addressed to
defendant UMEJESI, from the BOA
1004 Account

5/15/2017

Wire transfer of approximately
$30,000 from the BOA 1004 Account
to the BOA 9405 Account

6/7/2017

IRO,
IGBOKWE,
IKOGHO,
CATHEY, and
OCHIAGHA

6/23/2017

IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL

8/5/2017

Wire transfer of approximately
$47,000 from a Chase account ending
in 7522, held in Los Angeles,
California, to a Citibank account
of a Hong Kong company
Withdrawal of approximately $43,750
from a Chase account ending in 7633
of UICC 14, held in Culver City,
California, through check deposited
to a Chase account ending in 6781
of UICC 15 in Los Angeles,
California
Withdrawal of approximately
$47,606.40 from a Chase account
ending in 5092 of UICC 16, held in
Hawthorne, California (the “Chase
5092 Account”) through a cashier’s
check

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

8/5/2017

Withdrawal of approximately $52,602
from the Chase 5092 Account through
a cashier’s check

8/7/2017

Withdrawal of approximately $65,965
from the Chase 5092 Account through
a cashier’s check

8/8/2017

Withdrawal of approximately $35,000
from the Chase 5092 Account through
a cashier’s check

28
120

 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO,
IGBOKWE,
UMEJESI,
OGUNGBE,
CATHEY,
EKECHUKWU,
and SAM MAL
IRO and
AJAEZE

8/9/2017

Withdrawal of approximately $35,000
from the Chase 5092 Account through
a cashier’s check

8/10/2017

Withdrawal of approximately $35,000
from the Chase 5092 Account through
a cashier’s check

8/10/2017

Wire transfer of approximately
$60,000 from the Chase 5092 Account
to the BOA 2660 Account

8/15/2017

Wire transfer of approximately
$54,600 from the BOA 2660 Account
to a Chase account ending in 9931
of OGUNGBE, dba “P and P Motors
LLC,” held in Santa Fe Springs,
California.

8/15/2017

Deposit of a cashier’s check of
approximately $35,000, issued from
Chase 5092 Account, into a Chase
account ending in 5812 of UICC 16,
held in Inglewood, California
(“Chase 5812 Account”)

8/22/2017

Deposit of a cashier’s check of
approximately $35,000, issued from
the Chase 5092 Account, into the
Chase 5812 Account

1/19/2018

Wire transfer of approximately
$27,455 from a Chase account ending
in 0038 of defendant AJAEZE, held
in Carson, California (the “Chase
0038 Account”), to a Wells Fargo
account in the name “Cadon Auto
Corporation”
Wire transfer of approximately
$51,865 from the Chase 0038 Account
to a Mashreqbank PSC account, held
in the United Arab Emirates, in the
name “Elite Auto Fze”

24
25
26
27
28

IRO and
AJAEZE

1/19/2018

121

 1

IRO and
AJAEZE

1/31/2018

IRO and
AJAEZE

2/1/2018

IRO, IKOGHO,
and AJAEZE

2/15/2018

IRO, IKOGHO,
and AJAEZE

2/16/2018

IRO, IKOGHO,
and AJAEZE

2/16/2018

IRO and
AJAEZE

2/16/2018

IRO and
AJAEZE

2/16/2018

IRO and
AJAEZE

2/16/2018

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19

Wire transfer of approximately
$19,000 from the Chase 0038 Account
to a PNC Bank account of The George
Washington University to pay the
Spring 2018 tuition of a student
Purchase of cashier’s check of
approximately $12,793 from the
Chase 0038 Account
Wire transfer of approximately
$84,985 from the Chase 0038 Account
to a BOA account ending in 5903
Wire transfer of approximately
$189,000 from the Chase 0038
Account to a Compass Bank account
ending in 3681 of defendant IKOGHO,
held in Lynwood, California (the
“Compass Bank 3681 Account”)
Purchase of a cashier’s check of
approximately $35,000 from the
Compass Bank 3681 Account
Wire transfer of approximately
$200,000 from a Wells Fargo account
ending in 1849 of defendant AJAEZE,
held in Carson, California (the
“Wells Fargo 1849 Account”) to a
Wells Fargo account ending in 7748
of defendant AJAEZE, held in
Westchester, California (the “Wells
Fargo 7748 Account”)
Wire transfer of approximately
$500,000 from the Wells Fargo 1849
Account to the Wells Fargo 7748
Account
Wire transfer of approximately
$500,000 from the Wells Fargo 1849
Account to the Wells Fargo 7748
Account

20
21
22
23
24
25
26
27
28
122

 1

COUNT ONE HUNDRED SIXTY-ONE

2

[18 U.S.C. §§ 1960(a), (b)(1)(A), (b)(1)(B), (b)(1)(C); 2(a)]

3

[DEFENDANT IRO]

4

Beginning on a date unknown, and continuing at least until May

5

2, 2018, in Los Angeles County, within the Central District of

6

California, and elsewhere, defendant VALENTINE IRO, also known as

7

(“aka”) “Iro Enterprises,” aka “Valentine Obinna Iro,” aka “Obinna

8

Iro,” aka “Obinna Nassa,” doing business as (“dba”) V.O.I Enterprises

9

LLC, dba IRVA Auto Sales and Equip Broker LLC (“IRO”), knowingly

10

conducted, controlled, managed, supervised, directed, and owned an

11

unlicensed money transmitting business affecting interstate and

12

foreign commerce that (1) operated without an appropriate money

13

transmitting license in California where such operation is punishable

14

as a felony under state law; (2) failed to comply with the money

15

transmitting business registration requirements under Section 5330 of

16

Title 31, United States Code, and the regulations thereunder; and

17

(3) involved the transportation and transmission of funds that were

18

known to defendant IRO to have been derived from a criminal offense

19

and were intended to be used to promote and support unlawful

20

activity.

21
22
23
24
25
26
27
28
123

 1

COUNT ONE HUNDRED SIXTY-TWO

2

[18 U.S.C. §§ 1960(a), (b)(1)(A), (b)(1)(B), (b)(1)(C); 2(a)]

3

[DEFENDANTS IGBOKWE AND MANSBANGURA]

4

Beginning on a date unknown, and continuing at least until May

5

2, 2018, in Los Angeles County, within the Central District of

6

California, and elsewhere, defendants CHUKWUDI CHRISTOGUNUS IGBOKWE,

7

also known as (“aka”) “Christogunus C. Igbokwe,” aka “Chris Kudon,”

8

aka “Atete,” aka “Still Kudon” (“IGBOKWE”) and TITYAYE MARINA

9

MANSBANGURA, aka “Tityaye Igbokwe,” aka “Marina Mansour,” aka “Marina

10

Mansaray,” aka “Marina Tityaye Mans Bangura” (“MANSBANGURA”), each

11

aiding and abetting the other, knowingly conducted, controlled,

12

managed, supervised, directed, and owned an unlicensed money

13

transmitting business affecting interstate and foreign commerce that

14

(1) operated without an appropriate money transmitting license in

15

California where such operation is punishable as a felony under state

16

law; (2) failed to comply with the money transmitting business

17

registration requirements under Section 5330 of Title 31, United

18

States Code, and the regulations thereunder; and (3) involved the

19

transportation and transmission of funds that were known to

20

defendants IGBOKWE and MANSBANGURA to have been derived from a

21

criminal offense and were intended to be used to promote and support

22

unlawful activity.

23
24
25
26
27
28
124

 1

COUNT ONE HUNDRED SIXTY-THREE

2

[18 U.S.C. §§ 1960(a), (b)(1)(A), (b)(1)(B), (b)(1)(C); 2(a)]

3

[DEFENDANT IKOGHO]

4

Beginning on a date unknown, and continuing at least until

5

February 17, 2018, in Los Angeles County, within the Central District

6

of California, and elsewhere, defendant JERRY ELO IKOGHO, also known

7

as “J Man” (“IKOGHO”), knowingly conducted, controlled, managed,

8

supervised, directed, and owned an unlicensed money transmitting

9

business affecting interstate and foreign commerce that (1) operated

10

without an appropriate money transmitting license in California where

11

such operation is punishable as a felony under state law; (2) failed

12

to comply with the money transmitting business registration

13

requirements under Section 5330 of Title 31, United States Code, and

14

the regulations thereunder; and (3) involved the transportation and

15

transmission of funds that were known to defendant IKOGHO to have

16

been derived from a criminal offense and were intended to be used to

17

promote and support unlawful activity.

18
19
20
21
22
23
24
25
26
27
28
125

 1

COUNT ONE HUNDRED SIXTY-FOUR

2

[18 U.S.C. §§ 1960(a), (b)(1)(A), (b)(1)(B), (b)(1)(C); 2(a)]

3

[DEFENDANT UMEJESI]

4

Beginning on a date unknown, and continuing at least until 2018,

5

in Los Angeles County, within the Central District of California, and

6

elsewhere, defendant IZUCHUKWU KINGSLEY UMEJESI, also known as

7

(“aka”) “Kingsley Umejesi,” aka “Armenian Man,” aka “Kingsley LA,”

8

aka “Izuking Aka Aku” (“UMEJESI”), knowingly conducted, controlled,

9

managed, supervised, directed, and owned an unlicensed money

10

transmitting business affecting interstate and foreign commerce that

11

(1) operated without an appropriate money transmitting license in

12

California where such operation is punishable as a felony under state

13

law; (2) failed to comply with the money transmitting business

14

registration requirements under Section 5330 of Title 31, United

15

States Code, and the regulations thereunder; and (3) involved the

16

transportation and transmission of funds that were known to defendant

17

UMEJESI to have been derived from a criminal offense and were

18

intended to be used to promote and support unlawful activity.

19
20
21
22
23
24
25
26
27
28
126

 1

COUNT ONE HUNDRED SIXTY-FIVE

2

[18 U.S.C. §§ 1960(a), (b)(1)(A), (b)(1)(B), (b)(1)(C); 2(a)]

3

[DEFENDANT OGUNGBE]

4

Beginning on a date unknown, and continuing at least until 2018,

5

in Los Angeles County, within the Central District of California, and

6

elsewhere, defendant ADEGOKE MOSES OGUNGBE, also known as (“aka”) “P

7

& P Motors,” aka “Pp,” doing business as “P & P Motors LLC”

8

(“OGUNGBE”), knowingly conducted, controlled, managed, supervised,

9

directed, and owned an unlicensed money transmitting business

10

affecting interstate and foreign commerce that (1) operated without

11

an appropriate money transmitting license in California where such

12

operation is punishable as a felony under state law; (2) failed to

13

comply with the money transmitting business registration requirements

14

under Section 5330 of Title 31, United States Code, and the

15

regulations thereunder; and (3) involved the transportation and

16

transmission of funds that were known to defendant OGUNGBE to have

17

been derived from a criminal offense and were intended to be used to

18

promote and support unlawful activity.

19
20
21
22
23
24
25
26
27
28
127

 1

COUNT ONE HUNDRED SIXTY-SIX

2

[18 U.S.C. §§ 1960(a), (b)(1)(A), (b)(1)(B), (b)(1)(C); 2(a)]

3

[DEFENDANT MADEKWE]

4

Beginning on a date unknown, and continuing at least until

5

January 18, 2017, in Los Angeles County, within the Central District

6

of California, and elsewhere, defendant OBI ONYEDIKA MADEKWE, also

7

known as “Odu Investment” (“MADEKWE”), knowingly conducted,

8

controlled, managed, supervised, directed, and owned an unlicensed

9

money transmitting business affecting interstate and foreign commerce

10

that (1) operated without an appropriate money transmitting license

11

in California where such operation is punishable as a felony under

12

state law; (2) failed to comply with the money transmitting business

13

registration requirements under Section 5330 of Title 31, United

14

States Code, and the regulations thereunder; and (3) involved the

15

transportation and transmission of funds that were known to defendant

16

MADEKWE to have been derived from a criminal offense and were

17

intended to be used to promote and support unlawful activity.

18
19
20
21
22
23
24
25
26
27
28
128

 1

COUNT ONE HUNDRED SIXTY-SEVEN

2

[18 U.S.C. § 2232(a)]

3

[DEFENDANT IRO]

4

On or about July 19, 2017, in Los Angeles County, within the

5

Central District of California, prior to and during execution of a

6

federal search warrant by special agents of the Federal Bureau of

7

Investigation, defendant VALENTINE IRO, also known as (“aka”) “Iro

8

Enterprises,” aka “Valentine Obinna Iro,” aka “Obinna Iro,” aka

9

“Obinna Nassa,” knowingly destroyed, damaged, wasted, disposed of,

10

and transferred, and knowingly attempted to destroy, damage, waste,

11

dispose of, and transfer, a Samsung phone, Model Number SM-G925F,

12

with IMEI 359523064940172 and serial number R58G60161CA, for the

13

purpose of preventing and impairing the government’s lawful authority

14

to take such property into its custody and control.

15
16
17
18
19
20
21
22
23
24
25
26
27
28
129

 1

COUNT ONE HUNDRED SIXTY-EIGHT

2

[18 U.S.C. § 2232(a)]

3

[DEFENDANT IGBOKWE]

4

On or about July 19, 2017, in Los Angeles County, within the

5

Central District of California, prior to and during execution of a

6

federal search warrant by special agents of the Federal Bureau of

7

Investigation, defendant CHUKWUDI CHRISTOGUNUS IGBOKWE, also known as

8

(“aka”) “Christogunus C. Igbokwe,” aka “Chris Kudon,” aka “Atete,”

9

aka “Still Kudon,” knowingly destroyed, damaged, wasted, disposed of,

10

and transferred, and knowingly attempted to destroy, damage, waste,

11

dispose of, and transfer, a gold Apple iPhone 7, Model A1784, FCC ID:

12

BCG-E3092A, with IMEI 359217079598600 and serial number F2LSM1HZHFYH,

13

and a silver Samsung Galaxy Note 5, with IMEI 356000070040951 and

14

serial number RF8GA2MXBZD, for the purpose of preventing and

15

impairing the government’s lawful authority to take such property

16

into its custody and control.

17
18
19
20
21
22
23
24
25
26
27
28
130

 1

COUNT ONE HUNDRED SIXTY-NINE

2

[18 U.S.C. § 2232(a)]

3

[DEFENDANT EROHA]

4

On or about July 19, 2017, in Los Angeles County, within the

5

Central District of California, prior to and during execution of a

6

federal search warrant by special agents of the Federal Bureau of

7

Investigation, defendant CHUKS EROHA, also known as (“aka”) “Chuks

8

Nassa Iro,” aka “Nassa,” aka “Prince Chuddy,” aka “Nurse Chuddy,”

9

knowingly destroyed, damaged, wasted, disposed of, and transferred,

10

and knowingly attempted to destroy, damage, waste, dispose of, and

11

transfer, a black Apple iPhone 7 Plus, Model A1661, with IMEI

12

353818086081872 and serial number FCCSW9H3HFXW, for the purpose of

13

preventing and impairing the government’s lawful authority to take

14

such property into its custody and control.

15
16
17
18
19
20
21
22
23
24
25
26
27
28
131

 1

COUNT ONE HUNDRED SEVENTY

2

[18 U.S.C. § 1001(a)(2)]

3

[DEFENDANT IRO]

4

On or about July 19, 2017, in Los Angeles County, within the

5

Central District of California, in a matter within the jurisdiction

6

of the executive branch of the government of the United States of

7

America, namely, an investigation by the Federal Bureau of

8

Investigation (“FBI”) into the receipt and laundering of proceeds of

9

fraudulent schemes, defendant VALENTINE IRO, also known as (“aka”)

10

“Iro Enterprises,” aka “Valentine Obinna Iro,” aka “Obinna Iro,” aka

11

“Obinna Nassa” (“IRO”), knowingly and willfully made materially

12

false, fictitious, and fraudulent statements and representations.

13

Specifically, defendant IRO stated:

(1) that he had broken his

14

Samsung phone, Model Number SM-G925F, with IMEI 359523064940172 (the

15

“Samsung phone”) on the morning of July 18, 2017 following a fight

16

with his wife, a day prior to the execution of federal search

17

warrants by special agents of the FBI at his apartment in Carson,

18

California; and (2) that his breaking of the Samsung phone was

19

unconnected to the FBI’s execution of search warrants.

20

The statements were materially false, fictitious, and fraudulent

21

because, as defendant IRO then knew:

22

functioning and unbroken at the time that the FBI knocked on the door

23

of defendant IRO’s apartment in Carson, California at approximately

24

6:00 a.m. on July 19, 2017; and (2) defendant IRO broke his Samsung

25

phone at approximately 6:01 a.m. on or about July 19, 2017 after the

26

FBI knocked and announced its intention to execute search warrants.

27
28
132

(1) the Samsung phone was

 1

COUNTS ONE HUNDRED SEVENTY-ONE THROUGH TWO HUNDRED FORTY-NINE

2

[18 U.S.C. §§ 1028A(a)(1), 2(a)]

3

[DEFENDANTS IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, CATHEY,

4

MANSBANGURA, AJAEZE, EKECHUKWU, EROHA, OJIMBA, XPLORA G, OCHIAGHA,

5

N. DURU, OFORKA, MARK CHUKWUOCHA, NNAMDI, CHILAKA, OHAJIMKPO, UCHE,

6

ODIONYENMA, OGBONNA, ONWUASOANYA, MACWILLIAM CHUKWUOCHA, UZOKA, AWAK,

7

EGWUMBA, EZIRIM, OKAFOR, SAM MAL, MBA, IKEWESI, OGANDU, ANYANWU,

8

AZUBUIKE, NWACHUKWU, IZUNWANNE, OSUJI, ONYEKA, ANUNOBI, OKOLO, ONUWA,

9

ISAMADE, MADUFOR, NNEBEDUM, OKEREKE, ODIMARA, ONUDOROGU, NZENWAH,

10

OBASI, AGUBE, OKORIE, OHIRI, UGWU, AGWUEGBO, CHUKWU, MEGWA, P. DURU,

11

IWU, CHIKA, MEZIENWA, AGUH, ESHIMBU, ANOZIE, AGUNWA, G. DIKE,

12

UKACHUKWU, OSMUND, NWANGWU, AJAH, EJIOFOR, UBASINEKE, IBETO,

13

NWANEGWO, E. DIKE, EKI, IWUOHA, C. DURU, AND IHEJIUREME]

14
15
16

The Grand Jury re-alleges and incorporates paragraphs 1 through
8 of the Introductory Allegations of this Indictment here.
Beginning on or before October 7, 2014, and continuing through

17

at least May 2, 2018, in Los Angeles County, within the Central

18

District of California, and elsewhere, the following defendants

19

knowingly transferred, possessed, and used, without lawful authority,

20

a means of identification of another person during and in relation to

21

a felony violation of Title 18, United States Code, Section 1349,

22

Conspiracy to Commit Wire Fraud, Bank Fraud, and Mail Fraud, as

23

charged in Count Two:

24
COUNT

DEFENDANT

25
26
27
28

IRO
IGBOKWE
IKOGHO
UMEJESI
OGUNGBE
CATHEY
133

 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

MANSBANGURA
AJAEZE
EKECHUKWU
EROHA
OJIMBA
XPLORA G
OCHIAGHA
N. DURU
OFORKA
MARK CHUKWUOCHA
NNAMDI
CHILAKA
OHAJIMKPO
UCHE
ODIONYENMA
OGBONNA
ONWUASOANYA
MACWILLIAM CHUKWUOCHA
UZOKA
AWAK
EGWUMBA
EZIRIM
OKAFOR
SAM MAL
MBA
IKEWESI
OGANDU
ANYANWU
AZUBUIKE
NWACHUKWU
IZUNWANNE
OSUJI
ONYEKA
ANUNOBI
OKOLO
ONUWA
ISAMADE
MADUFOR
NNEBEDUM
OKEREKE
ODIMARA
ONUDOROGU
NZENWAH
OBASI
AGUBE
OKORIE
OHIRI
UGWU
AGWUEGBO
CHUKWU
MEGWA
IWU
CHIKA
134

 1
2
3
4
5
6
7
8
9
10
11

MEZIENWA
AGUH
ESHIMBU
ANOZIE
AGUNWA
G. DIKE
UKACHUKWU
OSMUND
NWANGWU
AJAH
EJIOFOR
UBASINEKE
IBETO
NWANEGWO
E. DIKE
EKI
IWUOHA
C. DURU
IHEJIUREME
MADEKWE

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
135

 1

COUNT TWO HUNDRED FIFTY

2

[18 U.S.C. §§ 1028A(a)(1), 2(a)]

3

[DEFENDANTS IRO, IGBOKWE, IKOGHO, UMEJESI, OGUNGBE, AND UZOKA]

4

Beginning on or before April 24, 2017, and continuing through at

5

least May 16, 2017, in Los Angeles County, within the Central

6

District of California, and elsewhere, defendants VALENTINE IRO, also

7

known as (“aka”) “Iro Enterprises,” aka “Valentine Obinna Iro,” aka

8

“Obinna Iro,” aka “Obinna Nassa,” CHUKWUDI CHRISTOGUNUS IGBOKWE, aka

9

“Christogunus C. Igbokwe,” aka “Chris Kudon,” aka “Atete,” aka “Still

10

Kudon,” JERRY ELO IKOGHO, aka “J Man,” IZUCHUKWU KINGSLEY UMEJESI,

11

aka “Kingsley Umejesi,” aka “Armenian Man,” aka “Kingsley LA,” aka

12

“Izuking Aka Aku,” ADEGOKE MOSES OGUNGBE, aka “P & P Motors,” aka

13

“Pp,” and EMMANUEL ONYEKA UZOKA, aka “Emmanuel Mansion,” aka

14

“Mansion,” aka “Son of God,” aka “Ezirim Uzoma,” each aiding and

15

abetting the other, knowingly transferred, possessed, and used,

16

without lawful authority, a means of identification of another person

17

during and in relation to a felony violation of Title 18, United

18

States Code, Section 1343, Wire Fraud, as charged in Count 26.

19
20
21
22
23
24
25
26
27
28
136

 1

COUNT TWO HUNDRED FIFTY-ONE

2

[18 U.S.C. §§ 1028A(a)(1), 2(a)]

3

[DEFENDANTS IRO, CATHEY, AND NNAMDI]

4

Beginning on or before April 12, 2017, and continuing through at

5

least April 24, 2017, in Los Angeles County, within the Central

6

District of California, and elsewhere, defendants VALENTINE IRO, also

7

known as (“aka”) “Iro Enterprises,” aka “Valentine Obinna Iro,” aka

8

“Obinna Iro,” aka “Obinna Nassa,” ALBERT LEWIS CATHEY, aka “Alb,” aka

9

“Abert Jag,” aka “Al,” and AUGUSTINE NNAMDI, aka “Nnamdi Augustine,”

10

aka “Jazz,” each aiding and abetting the other, knowingly

11

transferred, possessed, and used, without lawful authority, a means

12

of identification of another person during and in relation to a

13

felony violation of Title 18, United States Code, Section 1343, Wire

14

Fraud, as charged in Count 22.

15
16
17
18
19
20
21
22
23
24
25
26
27
28
137

 1

COUNT TWO HUNDRED FIFTY-TWO

2

[18 U.S.C. §§ 1028A(a)(1), 2(a)]

3

[DEFENDANTS IGBOKWE, MANSBANGURA, ODIONYENMA, and P. DURU]

4

Beginning on or before January 19, 2017, and continuing through

5

at least May 19, 2017, in Los Angeles County, within the Central

6

District of California, and elsewhere, defendants CHUKWUDI

7

CHRISTOGUNUS IGBOKWE, also known as (“aka”) “Christogunus C.

8

Igbokwe,” aka “Chris Kudon,” aka “Atete,” aka “Still Kudon,” CHIKA

9

AUGUSTINE ODIONYENMA, aka “Tony Augustin Odionyenma,” aka “Chika

10

Tony,” aka “CTA Finance Source Intl,” and TITYAYE MARINA MANSBANGURA,

11

aka “Tityaye Igbokwe,” aka “Marina Mansour,” aka “Marina Mansaray,”

12

aka “Marina Tityaye Mans Bangura,” each aiding and abetting the

13

other, knowingly transferred, possessed, and used, without lawful

14

authority, a means of identification of another person during and in

15

relation to a felony violation of Title 18, United States Code,

16

Section 1343, Wire Fraud, as charged in Count 24.

17

On or about the above dates and place, defendant PRINCEWILL

18

ARINZE DURU, aka “Arnzi Prince Will,” aka “Arinze,” knowingly and

19

intentionally aided, abetted, counseled, commanded, induced, and

20

procured the commission of the offense alleged above.

21
22
23
24
25
26
27
28
138

 1

FORFEITURE ALLEGATION ONE

2

[18 U.S.C. § 982 and 28 U.S.C. § 2461(c)]

3

1. Pursuant to Rule 32.2(a) of the Federal Rules of Criminal

4

Procedure, notice is hereby given that the United States will seek

5

forfeiture as part of any sentence, pursuant to Title 18, United

6

States Code, Section 982(a)(1) and Title 28, United States Code,

7

Section 2461(c), in the event of any Defendant’s conviction of the

8

offenses set forth in any of Counts One and Fifty-Two through One

9

Hundred Sixty-Six of this Indictment.

10
11

2.

States of America the following:

12
13

Any defendant so convicted shall forfeit to the United

(a)

Any property, real or personal, involved in such

offense, and any property traceable to such property; and

14

(b)

To the extent such property is not available for

15

forfeiture, a sum of money equal to the total value of the property

16

described in subparagraph (a).

17

3.

Pursuant to Title 21, United States Code, Section 853(p), as

18

incorporated by Title 18, United States Code, Section 982(b)(1), and

19

Title 18, United States Code, Section 982(b)(2), any defendant so

20

convicted shall forfeit substitute property, if, by any act or

21

omission of said defendant, the property described in the preceding

22

paragraph, or any portion thereof: (a) cannot be located upon the

23

exercise of due diligence; (b) has been transferred, sold to, or

24

deposited with a third party; (c) has been placed beyond the

25

jurisdiction of the court; (d) has been substantially diminished in

26

value; or (e) has been commingled with other property that cannot be

27

divided without difficulty. Substitution of assets shall not be

28

ordered, however, where the convicted defendant acted merely as an
139

 1

intermediary who handled but did not retain the property in the

2

course of the money laundering offense unless the defendant, in

3

committing the offense or offenses giving rise to the forfeiture,

4

conducted three or more separate transactions involving a total of

5

$100,000.00 or more in any twelve-month period.

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
140

 1

FORFEITURE ALLEGATION TWO

2

[18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]

3

1.

Pursuant to Rule 32.2 of the Federal Rules of Criminal

4

Procedure, notice is hereby given that the United States of America

5

will seek forfeiture as part of any sentence, pursuant to Title 18,

6

United States Code, Section 981(a)(1)(C) and Title 28, United States

7

Code, Section 2461(c), in the event of any Defendant’s conviction of

8

the offenses set forth in any of Counts Two through Forty-Nine of

9

this Indictment.

10
11

2.

Any defendant so convicted shall forfeit to the United

States of America the following:

12

(a)

All right, title, and interest in any and all

13

property, real or personal, constituting, or derived from, any

14

proceeds traceable to the offense; and

15

(b)

To the extent such property is not available for

16

forfeiture, a sum of money equal to the total value of the property

17

described in subparagraph (a).

18

3.

Pursuant to Title 21, United States Code, Section 853(p),

19

as incorporated by Title 28, United States Code, Section 2461(c), the

20

defendant, if so convicted, shall forfeit substitute property, up to

21

the value of the property described in the preceding paragraph if, as

22

the result of any act or omission of said defendant, the property

23

described in the preceding paragraph or any portion thereof (a)

24

cannot be located upon the exercise of due diligence; (b) has been

25

transferred, sold to, or deposited with a third party; (c) has been

26

placed beyond the jurisdiction of the court; (d) has been

27

substantially diminished in value; or (e) has been commingled with

28

other property that cannot be divided without difficulty.
141

 1

FORFEITURE ALLEGATION THREE

2

[18 U.S.C. § 982]

3

1.

Pursuant to Rule 32.2(a) of the Federal Rules of Criminal

4

Procedure, notice is hereby given that the United States of America

5

will seek forfeiture as part of any sentence, pursuant to Title 18,

6

United States Code, Section 982(a)(2), and Title 28, United States

7

Code, Section 2461(c), in the event of any defendant’s conviction of

8

the offenses set forth in any of Counts Fifty and Fifty-One of this

9

Indictment.

10
11
12

2.

Any defendant so convicted shall forfeit to the United

States of America the following:
(a) All right, title and interest in any and all property,

13

real or personal, constituting, or derived from, any proceeds

14

obtained, directly or indirectly, as a result of the offense; and

15

(b) To the extent such property is not available for

16

forfeiture, a sum of money equal to the total value of the property

17

described in subparagraph (a).

18

3. Pursuant to Title 21, United States Code, Section 853(p), as

19

incorporated by Title 18, United States Code, Section 982(b) and

20

Title 28, United States Code, Section 2461(c), any defendant so

21

convicted shall forfeit substitute property, up to the total value of

22

the property described in the preceding paragraph if, as the result

23

of any act or omission of said defendant, the property described in

24

the preceding paragraph, or any portion thereof: (a) cannot be

25

located upon the exercise of due diligence; (b) has been transferred,

26

sold to or deposited with a third party; (c) has been placed beyond

27

the jurisdiction of the court; (d) has been substantially diminished

28
142

 1

in value; or (e) has been commingled with other property that cannot

2

be divided without difficulty.

3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
143

 1

FORFEITURE ALLEGATION FOUR

2

[18 U.S.C. §§ 982 and 1028 and 28 U.S.C. §2461(c)]

3

1.

Pursuant to Rule 32.2 of the Federal Rules of Criminal

4

Procedure, notice is hereby given that the United States of America

5

will seek forfeiture as part of any sentence, pursuant to Title 18,

6

United States Code, Sections 982 and 1028 and Title 28, United States

7

Code, Section 2461(c) in the event of any defendant’s conviction of

8

the offenses set forth in any of Counts One Hundred Seventy-One

9

through Two Hundred Fifty-Two of this Indictment.

10
11
12

2.

Any defendant so convicted shall forfeit to the United

States of America the following:
(a) All right, title and interest in any and all property,

13

real or personal, constituting, or derived from, any proceeds

14

obtained, directly or indirectly, as a result of the offense;

15

(b)

Any personal property used or intended to be used to

16

commit the offense; and

17

(c)

To the extent such property is not available for

18

forfeiture, a sum of money equal to the total value of the property

19

described in subparagraphs (a) and (b).

20

3. Pursuant to Title 21, United States Code, Section 853(p), as

21

incorporated by Title 18, United States Code, Sections 982(b) and

22

1028(g), any defendant so convicted shall forfeit substitute

23

property, up to the total value of the property described in the

24

preceding paragraph if, as the result of any act or omission of said

25

defendant, the property described in the preceding paragraph, or any

26

portion thereof: (a) cannot be located upon the exercise of due

27

diligence; (b) has been transferred, sold to or deposited with a

28

third party; (c) has been placed beyond the jurisdiction of the
144

 court;

 

 

been commingled with other property that cannot be divided without

difficulty.

A TRUE BILL


7
Foreperbon

NICOLA T. HANNA
United States Attorney

Mavis/f

PATRICK R. FITZGERALD
Assistant United States Attorney
Chief, National Security Division

RYAN WHITE

Assistant United States Attorney

Chief, Cyber and Intellectual
Property Crimes Section

ANIL J. ANTONY

Assistant United States Attorney

Cyber and Intellectual Property
Crimes Section

145

has been substantially diminished in value; or has