Case: Document 1 Filed: 03/26/19 Page 1 Of 19 PageID A0 91 (Rev. 11/11) Criminal Complaint 1 AUSA Peter Sah! (A7) mp UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS MAR 2 6 2019b? EASTERN DIVISION THOMAS BRUTON CLERK, U. 3. DISTRICT COURT UNITED STATES OF AMERICA CASE NUMBER: V. UNDER SEAL WEIYUN HUANG, 1 9 also known as Kelly Huang COLE CRIMINAL COMPLAINT I, the complainant in this case, State that the following is true to the best of my knowledge and belief. From on? or about May 4, 2016, to on or about March 25, 2019, at Chicago, in the Northern District of Illinois, Eastern Division, and elSewhere, the defendant, violated: Code Section O?'ense Description Title 18, United States Code, Section conspiracy to commit visa fraud 371 This criminal complaint is baSed upon these facts: Continued on the attached sheet. ANDREW K. MCKAY Special Agent, Federal Bureau of Investigation (FBI) Sworn to before me and Signed in my presence. ?(ll Date: March 26. 2019 . ign UVH City and state: Chicago. Illinois JEFFREY 0L strate Judge rinted name and Title Case: Document 1 Filed: 03/26/19 Page 2 of 19 PageID UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS SS 1 I, ANDREW K. MCKAY, being duly sworn, state as follows: 1. I am a Special Agent with the Federal Bureau of Investigation (FBI), and have been so employed since approximately August 2014. My current responsibilities include the investigation of criminal violations relating to espionage offenses, including the gathering or delivery of defense information to aid a foreign government or agent, in violation of Title 18, United States Code, Section 794(a), and individuals who act as a foreign agent without notice to the Attorney General, in? violation of Title 18, United States Code, Section 951(a). I have conducted investigations involving the use of the Internet, email, and social media to further criminal activity. 2. This af?davit is submitted in support of a criminal complaint alleging that WEIYUN HUANG, also known as ?Kelly Huang,? has violated Title 18, United States Code, Section 371. Because this affidavit is being submitted for the limited purpose of establishing probable cause in support of a criminal complaint charging HUANG with conspiracy to commit visa fraud, I have not included each and every fact known to me concerning this investigation. I have set forth only the facts that I believe are necessary to establish probable. cause to believe that the defendant committed the offense alleged in the complaint. Case: Document 1 Filed: 03/26/19 Page 3 of 19 8. This af?davit is based on my personal knowledge, information provided to me by other law enforcement agents the information obtained during an ongoing investigation related to the defendant and other individuals. Background 4. Title 18, United States Code, section 1546(a) (visa fraud), makes it a criminal offense for any person that knowingly forges, counterfeits, alters, or falsely makes any immigrant or nonimmigrant visa, permit, border crossing card, alien registration receipt card, or other document prescribed by statute or regulation for entry into or as evidence of authorized stay or employment in the United States, or utters, uses, attempts to use, possesses, obtains, accepts, or receives any such visa, permit, border crossing card, alien registration receipt card, or other document prescribed by statute or regulation for entry into or as evidence of authorized stay or employment in the United States, knowing it to be forged, counterfeited, altered, or falsely made, or to have been procured by means of any false claim or statement, or to have been otherwise procured by fraud or unlawfully obtained. The US. Visa Program 5. The following information was obtained from the following US. Department of State website: and the US. Citizenship and Immigration Services website: a. A citizen of a foreign country (a foreign national) who seeks to enter the United States generally must first obtain a US. visa, which is placed in the traveler?s passport, a travel document issued by the traveler?s country of citizenship. Case: Document 1 Filed: 03/26/19 Page 4 of 19 PageID b. An F?l Visa permits a foreign nationalto study in the United States at university, college, high school, elementary school, seminary, conservatory, or other academic institution. Before applying for an F?l visa, students must ?rst be accepted by a Student and Exchange Visitor Program (SEVP) approved school. After - the SEVP-approved school accepts. a foreign national. as a student, the student Will be registered in the Student and Exchange Visitor Information System (SEVIS). The SEVP?approved school will issue the student a Form ?Certi?cate of Eligibility for onimmigrant Student Status For Academic and Language Students.? After the student receives the Form I-20 and registers in SEVIS, the student may apply at a US. Embassy or Consulate for a student (F or M) visa. The student must present the Form I-20 to the consular of?cer during the visa interview. c. i The Optional Practical Training (OPT) is temporary employment that is directly related to an F-l student?s major area of study. An F?l student could be authorized to receive up to a total of 12 months of practical training either before and/or after completion of studies. The post?completion OPT must be directly related to the student?s major area of study. students Who receive science, technology, engineering, and mathematics (STEM) degrees included on the STEM Designated Degree Program List, are employed by employers enrolled in E?Verify, and who have received an initial grant of post-completion OPT related to such a degree, may apply for a 24-month extension. A student must submit a Form Training Plan for STEM OPT Students in order to apply for the post-completion STEM OPT. Case: Document 1 Filed: 03/26/19 Page 5 of 19 PageID d. An visa permits a foreign national to work at a branch, parent, af?liate, or subsidiary of the current employer in a managerial or executive capacity, or in a position requiring specialized knowledge. Individual must have been employed?by the same employer abroad continuously for 1 year within the three preceding years. e. A and B-2 visas are visitor visas, which are nonimmigrant ?visas for personswho want to enter the United States temporarily for business (visa category for tourism (visa category B2), or for a combination of both purposes f. A foreign national must complete a Form DS-160 nonimmigrant visa application to apply for a visa. Findream, LLC 6. According to the California Secretary of State records, Findream, LLC was incorporated on or about August 30, 2013, by WEIYUN HUANG, with a listed address of 800 W. El Camino Real, Suite 180, Mountain View, California. On or about July 27, 2015, Findream ?led a ?Statement of Information,? in which HUANG listed herself as Findream?s CEO, and Individual Ale'as Findream?s manager. California Corporate Agents, Inc. was listed as Findream?s registered agent. On or about July 1 Law enforcement has identi?ed a person with the name of. Individual AW who previously resided at an address associated with Findream, LLC. However, as explained in more detail below, it appears that by no later than?2018, HUANG had begun using Individual name as an alias. Case: 1:19-cr-00275 Document 1 Filed: 03/26/19 Page 6 of 19 PageID 13, 2017, Findream ?led a ?Statement of No Change,? in which Kelly HUANG was listed as the CEO and preparer of the ?Statement of No Change.? 7. According to information obtained from open source databases, HUANG also uses the name ?Kelly 8. - According to information published on the Worldbase Records from Dun Bradstreet, Inc., HUANG is presently listed as-the ?Principal? for Findream, with the same above-listed address in Mountain View, California. I 9. According to information obtained from open- source databases, the address 800 W. El Camino Real, Suite 180, Mountain View, California'is associated with a Regus2 of?ce space for rent. 10. On or about March 25, 12019, agents 'Visited the website and observed the following webpage: FINDREAM IT Consulting. Let Us Do the Job. - Gel-Stun! 11. When agents scrolled down on the homepage for Findream.us, the following appeared on the same homepage: 2 According to Regus?s website, it provides ready?to-use of?ce workspace and co-work space. Case: Document 1 Filed: 03/26/19 Page 7 of 19 PageID About Us F's-um E: a sumo cc-rrpae, tutti-:9; :91 rd analog east} Mu Chis-?3 3'15 USI- :c ?395:: an: SUSIE: es ?7 the dais? ifr. From sag?99v; :c-acc dilator-ash; managavve-t: rd taxi-Ans 32:3? mango?rrt, 14.9 2:150:11: ?ed in cubed?; t: rd :9 up .1 :Nxe aging?? ten"- 233- "313:3??3, act-:5: z-e 5: ?ner-.3529: c.1319 cs: co, 12"?25154539 a'd upv?we. arcs: in 2.51415 3" 3 :bg?e?s the: ark-9 a: or; page: OUR SERVICES 9. -. stamps-age :ra omgcomer?; sci-ne'e CA . 1.313 snags: nus/res:- 9? (?r-nqpl?znn aers' ?my. \ru? ?aw 3 'dn-ur/EU A . seraces 12. Under the ?About? tab on the homepage, the following appears under a header entitled ?Our Team? that included the photograph, name, title, and job description of each individual: Case: Document 1 Filed: 03/26/19 Page 8 of 19 PageID 11. 1} 4' 3 Our Team . - . (I - Technology Manager ?co 0 - Social Media Manager 13. When agents did a Google ?reverse image sergirch?3 for each of the photographic images contained under ?Our Team,? on the Findreamus website, they discovered that each of the four images of the persons on the page was a ?stock image,?4 associated with a range of miscellaneous websites. In other words, the images did not appear to be images of the persons Findream purported them to be on its website. The following is an example of the reverse lookup search performed for the image purporting to be [Individual 3 Based on my training and experience, I know that a ?reverse image search? is a search engine technology that takes an image ?le as an input query and returns results related to the image. Google is a search engine that offer reverse image capability. 4 Based on my training and experience, I know that a ?stock image,? is an image that is commercially available or otherwise available on the internet and may be licensed for use. Case: 1:19-cr-00275 Document 1 Filed: 03/26/19 Page 9 of 19 PageID 5: I I #32835". m: o: f-ei'jr. a fusing mme m PA ASCM 1mm? ?aw-rm? cmrm'. mbx-ctiurIn? .c7g?a $11" A 'q 1? ?k . Coadmzed NUISIOQ Cate Means More Care 1 was mu: {mm-g? Jun-Ca#y1p5.\3.vj . - a1. ?1 ?92: Ari; fig'htq Core Hams Care and Accamwodabm WW liq-w; (.3 ?lm-wan k-rgn; "a v: .1 a H54 ?Kama ?kw :75'Nkf?y?va :5 ?fth "v'ij?i v?G'f?A it?d 129's" Ill- 1 Kiri-?v 5.55 5? 1'1" a; ?51:7 :5 2?31va: 3. awz? in! sum :51qu and NCLEX students {hrs rs hetp you succeed! ?391 . . N. .iIii', r? at?: 3w i 13:51? -f 5? '1 5 De?n'. Hui?, A- $5 7 g,g?g?nf?e- Nebraska Care mm staf?ng ?rm tic-We agency ccm? :?u?ww Ha".43 ?}Eaf"l' 94-2 Ma AWN-INN GO-z?ii?whois? search for the Findream website revealed that the domain was created on or about April 26, 2014, with GoDaddy as the registrar.5 The registrant listed the same 800 W. El Camino Real address in Mountain View, California, a phone number of 650-288?1224, and email account 5 Based on my training and experience, I know that 'a ?whois? search provides publicly available information as to which entity is responsible for a particular IP address. The ?whois? database contains the contact information for every registered domain. This includes information such as when the domain will expire, who owns the domain, and who is the registrar for the domain. Case: 1:19-cr-00275Document 1 Filed: 03/26/19 Page 10 of 19 PageID #:10 15. When agents performed a Google search of the phone number 650-288- 1224, the Findream website was the third listed result, while the ?rst listed result was for the website ww w. chineselook ingforjob. com 16. On or about March 25, 2019, agents Visited the website and discovered the website is predominately in the Chinese language. The following excerpts from the website are based upon draft English translations of the Chinese writing on the website completed by interpreters employed by the FBI: FAQ regarding OPT affiliation (key points!) Q: What are included in the first year OPT affiliation? We charge one time membership fee of $200, which includes Offer, employee admission procedure and follow up Background Check . . . Q: Are you a legal entity? A: Our company headquarters is located in New York, with branch of?ces in Silicon Valley, Chicago and LOs Angeles. Our business is IT consultation. We maintain good tax reporting records, is Everify. We possess for employees, green card (generally, some so-called af?liation companies are unable to do all these). Our customers are all 'over China and" the U.S., [they] need large amount of Workers to complete tasks. While helping students resolve status issues, we also provide quali?ed students work, both Paid and Unpaid, in CS, statistics and math. Q: What is OPT affiliation? A: The theory behind af?liation is ?nding a company, become an employee, and then send the company?s information, to the school, which will then enter your information to your SEVIS system. When you receive 120, [you] will see that this company is on 120. By doing so, USCIS will think your status is legal. Case: Document 1 Filed: 03/26/19 Page 11 of 19 PageID #:11 Q: Do I need affiliation? A: Under the new 2016 policy, the school and USCIS have strict regulations for graduates. Students not working 90 days after EAD card is issued will have dif?culty applying for or OPT?Extension might be rejected. For security reasons, we suggest all graduates wishing to stay in the U.S. ?nd companies to af?liate to prevent future risks. Q: What are the benefits of affiliation? A: Since af?liation is ?pretend? work, inexperienced students usually do not write as work experience in resumes. If this part is well prepared, it will look real. We have seen some students doing so and they found satisfying job after all. Q: Able to provide OPT Extension affiliation? A: Yes, but number is limited. Please send resume to customer service Email: optguakaoca@gmail.com. Our Main Goal Chineselookingforjob.com is a branch office that mainly provides consultation to job seekers in the U.S. The company has ?North American jobseekers? WeChat subscription number, media and training services. The goal is to help overseas Chinese ?nd jobs after graduation. We have large Mentor networks in all major companies in the U.S. to provide suggestions and service to graduating Chinese students. In the past two years, CLFJ has helped more than 200 students with job related issues. We will continue providing the best service to overseas Chinese in the future. Get Involved Contact Us optguakaoca@gmail.com WeChat subscription number: (North American jobseekers) Phone number: 650?288-1224 17. Based upon the draft translation of the website, my training and experience, and the information obtained from the investigation to date, it appears that the entire purpose of chineselookingforjob.com is to provide false veri?cations of employment for Chinese nationals who are F?l visa holders seeking to continue their stay in the United States via the OPT program. Indeed, the website characterizes 10 Case: 1:19-cr-00275 Document 1 Filed: 03/26/19 Page 12 of 19 PageID #:12 OPT af?liation as ?pretend? employment, and speci?cally indicates the intent to convince the United States Citizenship and Immigration Services (USCIS) that the individual?s status is ?legal.? Further, according to Google?s ?translate? feature, the term ?gua kaoca? means ?affiliated.? Therefore, the email, address optguakaoca@gmail.com includes the words and the Chinese word for ?af?liated? in its handle. 18. Based on my training and experience, I believe that if a Chinese national sought placement services from chineselookingforjobcom, that individual would be given Findream as their ?af?liated? employer to list on their relevant visa paperwork. 19. Notably, since-Findream?s creation in approximately 2013, based upon a search of the SEVIS system, approximately 1,900 F?l visa-holders have listed Findream as an employer on their OPT forms, including JI Chaoqun, discussed further below. WEIYUN HUANG 20. According to the Department of State, on or about May 21, 2009, HUANG, was issued a 12?month F?l visa for her to study at the University of Mississippi. She was issued additional 12?month F?l visas for her studies at the University of Mississippi through 2014. On all of HUAN G?s F-l visa applications after 2010, HUANG listed kelly0710@gmail.com as her email address. 21. According to the Department of Homeland Security, Lon or about June 1'7, 2014, HUANG was issued a 24-month visa to accompany her husband 11 Case: Document 1 Filed: 03/26/19 Page 13 of 19 PageID #:13 during his sponsored employment in the United States. On the June 2014 L-2 visa application, HUANG listed Findream as her employer. 22. According to the Google subscriber records for optguakaoca@gmail.com, I the recovery email for optguakaoca@gmail.com is kelly0710@gmail.com. The kelly0710@gmail.com email account is the same one used by HUANG, as detailed . above. HUANG is thus connected to both chineselookingforjobcom and Findream, the latter of which she is the founder. I 23. Based upon a review of email search warrants and subpoena returns, frOm approximately August 2013 to approximately March 2018, Findream deposited approximately $584,269 into its bank accounts, approximately $317,766 of Which came from accounts held by HUANG. 24. Based upon a review of email search warrants and subpoena returns, from approximately May 2013 to approximately June 2018, HUANG deposited approximately $1.64 million into her own bank accounts, including over $985,000 received from individuals via peer-to?peer payments services, suchras PayPal and Venmo. Findream directed ?employees? to submit the application fee via PayPal among other services to HUANG directly. During that same timeframe, HUANG spent over $715,000 on credit card bills. Her credit card spending activity included signi?cant expenditures at luxury retail stores, such as Neiman Marcus, Louis Vuitton, Hermes, Chanel, and Prada. As a result, HUANG appears to be operating Findream for her own personal gain. Based on a review of the bank records, there 12 Case: 1 Filed: 03/26/19 Page 14 of 19 PageID #:14 appears to be only a small amount of possibly legitimate business expenses, other than payments to Regus for of?ce space. JI CHAOQUN 25. According to the Department of State, on or about August 28, 2013, I CHAOQUN was born in China and arrived in the United States from Beijing, China, on a 12?month F?l Visa, for the purpose of studying in the United States at a university in Chicago (?University On or about January 30, 2015, I was issued his second 12?month F-l visa for continued study at University A. JI submitted the requisite I-20 Forms in support of each F?l visa. In 2015, he received his Master?s Degree in Electrical Engineering at University A. 26. In anticipation of his graduation in December 2015, on or about October 20, 2015, I submitted an I-20 Form seeking authorization to pursue post-completion Optional Practical Training (OPT) for the time period of February 17, 2016 through February 16, 2017. 27. According to University A, on or about November 28, 2016, I submitted a Form I-983 Training Plan-for STEM OPT Students for the timeframe of February 17, 2017, through February 16, 2019, which included, but not limited to, the following information: a. In Section 2, I certi?ed under penalty of perjury the accuracy of the statements contained in the Form b. In Section 3, J1 listed his employer as Findream, LLC, with an address at 800 El Camino Real, Suite 180, Mountain View, CA, and a website 13 Case: Document 1 Filed: 03/26/19 Page 15 of 19 PageID #:15 address of I listed his start date as November 14, 2016, that he was scheduled to work 25 hours per week, and that his salary was $20 per hour, to be paid on a basis. c. In Section 4, an individual purporting to be ?[Individual Director of Human Resources,? certi?ed on behalf of Findream under penalty of perjury that I was an employee of Findream and that I and Findream would comply with the requirements of the STEM OPT program. I d. In Section 5, J1 listed his employment at Findream?s Chicago Of?ce at 55 East Monroe Street, Suite 3800. The local Findream of?cial listed was Under the ?Student Role? portion of Section 5, the following is an excerpt of what is written: ?This student works as a Software engineer in .our company, her6 job duties includes but not limited to the following, write well designed, testable, ef?cient code by using best software development practices . . . e. In Section 6, a person purporting to be Individual AW again certi?ed on behalf of Findream under penalty of perjury that the information contained in this STEM OPT Training Plan was true and correct. f. On or about February 19, 2018, I and a person purporting to be Individual AW certi?ed under penalty of perjury an evaluation of progress to date. 5 This is the wrong gender for JI, which, based on my training and experience, is further evidence that Findream did not know who they were allegedly employing. 14 Case: 1 Filed: 03/26/19 Page 16 of 19 PageID #:16 g. Based upon a review of email search warrants and subpoena returns associated with HUANG and Findream, from May 2013 to June 2018, there are no records of Individual AW receiving income from Findream or HUANG. h. Based upon my trainingand experience, and records obtained via grand jury subpoena and/or court authorization, I believe HUANG uses the name of Individual AW to verify some human resources documents related to Findream in an effort to legitimize the company by appearing large enough to necessitate having a ?Human Resources Manager.? I also believe that HUANG is using Individual name as an alias and is personally handling most of the administrative functions related to Findream. Speci?cally, Google records reveal that email addresses associated with HUANG are linked by cookies to email addresses associated with Individual AW. Additionally, logins to email addresses associated with HUANG and Individual AW came from the exact same IP addresses within minutes of each other. i. An email search warrant for kelly0710@gmail.com revealed two documents related to JI Chaoqun?s purported employment with Findream stored in the Google Drive" for kelly0710@gmail.com. The ?rst document is an ?Employment Offer Letter? dated April 4, 2016, and purportedly signed by Individual AW. The 7 According to Google, Google Drive is a ?le storage and service developed by Google. Launched on April 24, 2012, Google Drive allows users to store ?les on their servers, ?les across devices, and share ?les. In addition to a website, Google Drive offers apps with of?ine capabilities for Windows and macOS computers, and Android and smartphones and tablets. Google Drive encompasses Google Docs, Sheets, and Slides, an of?ce suite that permits collaborative editing of documents, spreadsheets, presentations, drawings, forms, and more. Files created and edited through the of?ce suite are saved in Google Drive. - 15 Case: 1:19-cr-00275 Document 1 Filed: 03/26/19 Page 17 of 19 PageID #:17 second document is an ?Employment Veri?cation Letter? dated January 9, 2017, and purportedly signed by Individual AW. . 28. According to the Department of State, on or about January 9, 2017, I executed another 1-20 Form, in which he stated that he began Post?Completion OPT employment at Findream, LLC, on April '25, 2016, and was authorized for STEM OPT employment at Findream, LLC, until February 17, 2019. 29. On or about May 1, 2018, agents visited the Findream Chicago of?ce, purportedly located at 55 East .Monroe Street, Suite 3800. The security guard/receptionist for the building was unfamiliar with any company named ?Findream.? The security guard stated that Suite 3800 contained a Regus of?ce location. At the Regus of?ce at Suite 3800, a Regus receptionist also stated that she was unfamiliar with any company named ?Findream.? The receptionist stated she knew most of her clients at that location and never heard of ?Findream?, she also I conducted internal database checks and could ?nd no records for ?Findream? for the Regus of?ce at 55 E. Monroe St., Suite 3800. 30. According to I?s Chase bank records, on or about November 17, 2016, I paid Findream LLC $900, which, as discussed below, appeared to be a payment for the veri?cations of employment contained on I?s OPT forms. A review of I?s bank account records at Chase, Citibank, and Bank of America revealed no income from Findream. Based on the investigation to date, these three. bank accounts are the only U.S.?based bank accounts held by I. 16 Case: 1:19-cr-00275 Document 1 Filed: 03/26/19 Page 18 of 19 PageID #:18 31. According to records obtained via subpoena for HUAN G?s Chase bank records, on or about May 4, 2016, HUAN G?s personal account received $200 from I via Chase QuiCkpay, which appears to be consistent with the affiliation fee. According to subpoena records for Bank of America bank records, on or about ?November 17, 2016, personal account received $900 from JI via Chase Quickpay. These payments and timing are consistent with I?s start date listed on the of November 14, 2016, and the start date listed on the Employment Veri?cation Letter of November 17, 2016. 32. On or about September 25, 2018, I was arrested and charged by complaint in this district with acting as an agent of a foreign government, namely the People?s Republic of China, without prior notice to the Attorney General, in violation ofTitle 18,. United States Code, Section 951(a) (case'number 18 CR 611, Guzman, J.). I waived his Miranda rights and participated in a post?arrest interview. During that interview, JI acknowledged that he paid Findream $900, that he never actually worked for Findream,that he was never paid by Findream, and that he used the company to falsely verify his employment on the OPT form in order to fraudulently extend his stay in the United States. 17 Case: 1:19-cr-00275 Document 1 Filed: 03/26/19 Page 19 of 19 PageID #:19 33. Based on the investigation of Findream to date, Findream appears to be a company on paper only, With no actual physical presence, and was created for the sole purpose of providing false veri?cations of employment to F-l visa holders seeking to extend their stay in the U.S. viathe OPT program. FURTH AFFIANT SAYETH NOT. ANDREW K. MCKAY 25 Special Agent, Federal Bureau of Investigation UBSCRIBED to before me on March 26, 2019. 4A . nit Eagistrate Judge 18