Case 1:20-cr-00086-KMW Document 1 Filed 10/29/19 Page 1 of 16

ORIGINAL

,.
Approved :
SA~

Assistant United States Attorney
Before :

THE HONORABLE JAMES L . COTT

~MAG 1 o17

United States Magistrate Judgel {
Southern District of New York
;:J

- - - - - - - - - - -x
SEALED COMPLAINT

UNITED STATES OF AMERICA
Viola t ions of
18 u. s . c . §§ 371 ,
1349 , and 1956

- v. -

JOSEPH IORHEMBA ASAN JR ., and
CHARLES IFEANYI OGOZY ,

COUNTY OF OFFENSE :
NEW YORK & WESTCHESTER

Defendants .

-x
SOUTHERN DISTRICT OF NEW YORK , ss .:
VINCENT Q. LAI , being duly sworn , deposes and says that he
is a Special Agent with the Federal Bureau of Investigation
( " FBI " ) , and charges as follows :
COUNT ONE
(Conspiracy to Commit Bank Fraud and Wire Fraud)

l .
From at least in or about February 2018 through at
least in or about September 2019 , in the Southern District of
New York and elsewhere , JOSEPH IORHEMBA ASAN JR . and CHARLES
IFEANYI OGOZY , the defendan t s , and others known and unknown ,
willfully and knowingly did combine , conspire , confederate , and
agree together and wi th each other to commit wire fraud , in
violation of Title 18 , United States Code , Section 1343 , and
ba nk fraud , in violation of Title 18 , United States Code ,
Section 1344 .
It was a part and an object of the conspiracy that
2.
JOSEPH IORHEMBA ASAN JR. and CHARLES IFEANYI OGOZY , the
defendants , and others known and unknown , having devised and
intending to devise a scheme and artifice to defraud and for
obtaining money and property by means of false and fraudulent
pretenses , representations , and promises , willfully and
knowingly would and did tran9m1 t ~n ~ GaUue to be tranumitted by

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means of wire , radio , and television communication in interstate
and foreign commerce , writings , signs , signals , pictures , and
sounds for the purpose of executing such scheme and artifice, in
violation of Title 18 , United States Code , Section 1343 .
3.
It was further a part and an object of the conspiracy
that JOSEPH IORHEMBA ASAN JR . and CHARLES IFEANYI OGOZY , the
defendants , and others known and unknown , willfully and
knowingly would and did execute and attempt to execute a scheme
and artifice to defraud a financial institution , the deposits of
which were then insured by the Federal Deposit Insurance
Corporation ("FDIC") , and to obtain moneys , funds , credits ,
assets , securities , and other property owned by , and under the
custody and control of , such financial institution , by means of
false and fraudulent pretenses , representations , and promises ,
in violation of Title 18 , United States Code , Section 1344.
(Title 18 , United States Code , Section 1349.)
COUNT TWO
(Conspiracy to Receive Stolen Property)

4.
From at least in or about February 2018 through at
least in or about September 2019, in the Southern District of
New York and elsewhere , JOSEPH IORHEMBA ASAN JR. and CHARLES
IFEANYI OGOZY , the defendants , and others known and unknown ,
willfully and knowingly did combine , conspire , confederate, and
agree together and with each other to commit offenses against
the United States , to wit , a violation of Title 18 , United
States Code , Section 2315 .
5.
It was a part and object of the conspiracy that JOSEPH
IORHEMBA ASAN JR . and CHARLES IFEANYI OGOZY , the defendants , and
others known and unknown , would and did receive , possess ,
conceal , store , barter , sell , and dispose of goods , wares ,
merchandise , securities , and money , of the value of $5 , 000 and
more , which had crossed a state boundary after being stolen ,
unlawfully converted , and taken , knowing the same to have been
stolen , unlawfully converted , and taken , in violation of Title
18 , United States Code , Section 2315.
OVERT ACTS
6.
In furtherance of said conspiracy and to effect the
illegal object thereof , the following overt acts , among others ,
were committed in the Southern District of New York and
E;olsewhere :
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a.
On or about February 28 , 2019 , JOSEPH IORHEMBA
ASAN JR . , the defendant , received a wire transfer of
approximately $421 , 722 consisting of fraud proceeds in a
business bank account ASAN controlled.

b.
Between in or about March 2018 and in or about
March 2019 , CHARLES IFEANYI OGOZY , the defendant , received
approximately $77 , 000 in bank accounts that OGOZY controlled
from business bank accounts controlled by ASAN that received
fraud proceeds .
(Title 18 , United States Code , Section 371 . )
COUNT THREE
(Money Laundering Conspiracy)

7.
From at least in or about February 2018 through at
least in or about September 2019 , in the Southern District of
New York and elsewhere , JOSEPH IORHEMBA ASAN JR . and CHARLES
IFEANYI OGOZY , the defendants , and others known and unknown ,
willfully and knowingly did combine , conspire , confederate , and
agree together and with each other to commit money laundering ,
in violation of Title 18 , United States Code , Section
1956(a) (1) (B) (i) .
8.
It was a part and object of the conspiracy that JOSEPH
IORHEMBA ASAN JR . and CHARLES IFEANYI OGOZY , the defendants , and
others known and unknown , knowing that the property involved in
certain financial transactions represented proceeds of some form
of unlawful activity , would and did conduct and attempt to
conduct such financial transactions , which in fact involved the
proceeds of specified unlawful activity , to wit , the wire fraud
and bank fraud conspiracy charged in Count One of this
Complaint , knowing that the transactions were designed in whole
and in part to conceal and disguise the nature , location ,
source , ownership , and control of the proceeds of specified
unlawful activity , in violation of Title 18 , United States Code ,
Section 1956(a) (1) (B) (i) .
(Title 18 , United States Code , Section 1956(h) . )
The bases for my knowledge and for the foregoing charges
are , in part , as follows :
9.
I am a Special Agent with the FBI and I have been
personally involved in the investigation of this matter . This
affidavit is based upon my conver~~t~~n~ w~th law enforcement
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agents , witnesses , and others , as well as my examination of
report and records . Because this affidavit is being submitted
for the limited purpose of establishing probable cause , it does
not include all the facts that I have learned during the course
of my investigation . Where the contents of documen t s and the
actions , statements , and conversations of others are reported
herein , they are repor t ed in substance and in part , except where
otherwise indicated . Where figures , calc ul ations , a n d dates a r e
set forth herein , they are approximate , unless stated otherwise .
Overview of the Conspiracy
10 . Since in or about February 2018 , JOSEPH IORHEMBA ASAN
JR . and CHARLES IFEANYI OGOZY , the defendants , who are both
members of the U. S . Army Reserves , participated in a scheme to
commit fraud against victims across the United States , defraud
banks , and to launder fraud proceeds in bank accounts that they
controlled . Among other things , ASAN and OGOZY opened bank
accounts in the names of fake businesses ; received or attempted
to receive over $3 million in fraud proceeds ; and wi thdrew fraud
proceeds in cash and/or transferred fraud proceeds to other co conspirators , including to each other .
11 . The funds laundered by JOSEPH IORHEMBA ASAN JR . and
CHARLES IFEANYI OGOZY , the defendants , were obtained primarily
through (a) business email compromises , in which members of the
scheme gained unauthorized access to or spoofed email accounts
and impersonated employees of a company or third parties engaged
i n business with the company in order to fraudulently induce t h e
victims to transfer money to bank accounts under the control of
members of the scheme , including ASAN and OGOZY ; and (b) romance
scams , in which members of the scheme de l uded unsuspecting older
women and men into believing they were in a romantic
relationship with a fake identity assumed by members of the
scheme and used false pretenses to cause the victims to transfer
money to bank accounts under the control of members of the
scheme , including ASAN and OGOZY.
12 . Based on my review of U. S . Army records for JOSEPH
IORHEMBA ASAN JR . and CHARLES IFEANYI OGOZY , the defendants ,
i ncluding security clearance applications submitted by them , I
have learned the following , in substance and in part :
ASAN and OGOZY have been members of the U. S . Army
a.
Reserves from in or about February 2018 through the present .

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States .

b.
ASAN is a dual citizen of Nigeria and the United
OGOZY is a citizen of Nigeria .

ASAN ' s phone number of record ends in 9208
c.
" Asan Phone Number " ) .

(the

d.
OGOZY ' s phone number of record ends in 3892 (the
" Ogozy Phone Number " ) .
e.
ASAN is associated with an address in Carteret ,
New Jersey (the " Carteret Address " ) and an address in Daytona
Beach , Florida (the "Daytona Beach Address " ) .
OGOZY is associated with an address in
f.
Hackensack , New Jersey and an address in West Chester , Ohio (the
" West Chester Address " ) .
Victim- 1 , Victim- 2 , and Victim- 3
13 . Based on the FBI ' s investigation of a business email
compromise involving a large equipment distributor located in
Pennsylvania ("Victim- 1 " ) , including the FBI ' s interview of an
executive of Victim- 1 and documents provided by Victim- 1 to the
FBI , I have learned the following , in substance and in part :
a.
In or about early 2019 , Victim- 1 agreed to sell
equipment to a chemical distributor located in New Jersey
(" Victim- 2") for approximately $421 , 722.
In connection with
this transaction , Victim-1 and Victim- 2 utilized a broker
located in Melville , New York ("Victim- 3 " ) .
On or about February 28 , 2019 , an individual
b.
purporting to be from Victim- 1 sent Victim-3 an email
representing , in substance and in part , that payment for the
above - described transaction should be deposited in a bank
account ("Uxbridge Account - 1 " ) in the name of Uxbridge Capital ,
LLC (" Uxbridge " ) at a credit union for active duty , retired , and
reserve U. S . Armed Forces personnel ("Bank-1 " ). As a result ,
Victim-3 initiated a transfer of approximately $421 , 722 from
Victim- 2 to Uxbridge Account - 1. The wire was processed in
Yonkers , New York .
c.
Victim- 1 has never done business with Uxbridge
and did not authorize the transfer to Uxbridge Account - 1 .

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14 . Based on my review of bank records for Uxbridge
Account - 1 at Bank- 1 , I have learned the following , in substance
and in part :
On or about February 28 , 2019 , Uxbridge Account - 1
a.
received a deposit of approximately $421 , 722 .
b.
On or abo u t March 1 , 2019 , Bank- 1 was advised
that the wire instructions provided to Victim- 3 were fraudulent
and recalled the wire transfer . As a result of the recall of
the wire transfer , Uxbridge Account - 1 was frozen by Bank- 1 .
c.
Between on or about March 5 and 26 , 2019 , when
Uxbridge Account - 1 was frozen due in part to the fraudulent wire
transfer from Victim-2 , JOSEPH IORHEMBA ASAN JR ., the defendant ,
called Bank- 1 multiple times to inquire why he was not able to
access Uxbr i dge Account - 1 .
Victim- 4
15 . Based on the FBI ' s investigation of a business email
compromise involving a Marine Corps veterans organization
(" Victim-4 " ) , including the FBI ' s interview of an executive of
Victim- 4 (the " Victim- 4 Executive " ) and documents provided by
Victim- 4 to the FBI , I have learned the following , in substance
and in part :
a.
On or about August 9 , 2018 , an individual
purporting to be the Victim- 4 Exec u tive sent unauthorized emails
using the Victim- 4 Executive ' s email address to the treasurer of
Victim- 4 requesting a wire transfer of $6 , 850 . 20 to an account
in the name of Uxbridge (" Uxbridge Account - 2 " ) at a bank
headquartered in Manhattan (" Bank- 2 " ) . As a result , the
treasurer of Victim-4 initiated the wire transfer request .
At no time did the Victim- 4 Executive authorize
b.
the above-described wire transfer.
16 . Based on my review of bank records for Uxbridge
Account-2 at Bank- 2 , I have learned , in substance and in part ,
that on or about August 10 , 2018 , Uxbridge Account - 2 received a
wire transfer of $6 , 850 . 20 from Victim- 4 .
Victim- 5
17. Based on the FBI ' s investigation of a romance scam
involving a female individual ("Victim- 5 " ) , including the FBI ' s
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interview of Victim- 5 and documents provided by Victim-5 to the
FBI , I have learned the following , in substance and in part :
a.
Victim- 5 was a 67 - year - old woman residing in
North Carolina who began to u se an online dating website for
individuals aged 50 and older after her husband had passed away .
Through that online dating website , Victim- 5 began an onl i ne
relationship with a purported male individua l (" Individual - 1 " )
who represented himself to have a son and daughter i n Canada .
b.
Vict i m- 5 commu nicated wit h Individual - 1 through
phone calls , text messages , and ema i ls . Although Victim- 5 did
not meet Individual - 1 in person , Individual - 1 sent Victim- 5
photos of himself , includ i ng a copy of his purported U. S .
passport .
In add i tion , individuals purporting to be Individual l ' s daughter and lawyer also contacted Victim- 5 on behalf of
Individual - 1 .
c.
At some point during the course of their
relat i onship , Individual - 1 to l d Victim- 5 , in substance and in
part , that he was in the Phil i ppines working as an engineer on a
bridge and that he was unable to access his American bank
accounts because someone had committed bank fraud and deposited
money into his account . Individual - 1 subsequently requested
that Victim- 5 send money to him , and Individual-1 informed
Victim- 5 that Individual - 1 wou l d pay Victim- 5 back wi th
interest . Individual - 1 instructed Victim- 5 to transfer money
to , among other accounts , Uxbridge Account - 2 .
d.
As a result of the representations made by
Individual-1 , on or about August 30 , 2018 , Victim- 5 transferred
approximately $75 , 000 to Uxbridge Account - 2 .
e.
Individual - 1 .

Victim- 5 never received any money from

18 . Based on my review of bank records for Uxbridge
Account - 2 at Bank- 2 , I have learned , in substance and in part ,
that on or about August 30 , 2018 , Uxbridge Account - 2 received a
wire transfer of approximately $75 , 000 from Victim- 5 .
Victim- 6
19 . Based on the FBI ' s investigation of a business email
compromise involving a home mortgage company (" Victim-6 " ) ,
including the FBI ' s interview of two employees of Victim- 6 and

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documents provided by Victim- 6 to the FBI , I have learned the
following , in substance and in part :
On or about November 2 , 2018 , an ind i vidual
a.
purporting to be the chief executive officer of Victim- 6 (the
" Victim- 6 Executive " ) sent an email to the accounting manager of
Victim- 6 requesting a wire transfer of approximately $18 , 280 to
an account in the name of Uxbridge (" Uxbridge Account - 3 " ) at a
community bank headquartered in Bayonne , New Jersey ("Bank - 3 " )
As a result , the accounting manager of Victim- 6 initiated the
wire transfer .
b.
At no time did the Victim- 6 Executive authorize
the above - described wire transfer .
20 . Based on my review of bank records for Uxbridge
Acco u nt - 3 at Bank- 3 , I have learned , in substance and in part ,
that on or about November 2 , 2018 , Uxbridge Account - 3 received a
wire transfer of approximately $18 , 280 from Victim- 6 , which was
l ater reversed due to f r aud .
Victim- 7
21 . Based on the FBI ' s investigation of a romance scam
involving a female individual ("Victim- 7 " ) , including the FBI ' s
interview of Victim- 7 and my review of documents provided by
Victim- 7 to the FBI , I have learned the following , in substance
and in part :
a.
Victim- 7 was a 57 - year - old woman residing in
Illinois who began a relationship through an online dating
website with a purported male individual (" Individual - 2 " ) who
represented that he lived in Newark , New Jersey .
Victim- 7 communicated with Individual - 2 through
b.
phone calls , text messages , and emails . Although Victim- 7 did
not meet Individual - 2 in person , Individual - 2 sent Victim- 7
photos of himself , including a copy of his purported New Jersey
driver ' s license .
In addition , an individual purporting to be a
financial consultant contacted Victim- 7 on behalf of Individual 2.

c.
At some point during the course of their
relationship , Individual - 2 told Victim- 7 , in substance and in
part , that he was in Dubai working on an engineering project
where a member of his team was hurt on the job .
Individual - 2
. ~q ~ ~~t~¢ that Victim-7 send money to Individual - 2 to help the
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injured employee . In addition , Individual - 2 also requested that
Victim- 7 send Individual - 2 money related to a $1 . 9 million
investment , of which Indivi d ual - 2 promised Vi ctim- 7 that she
would receive half .
Individual - 2 instructed Victim- 7 to transfer
d.
money to , among other accounts , an account in the name of
Renegade Logistics , LLC (" Renegade " ) in Florida .
I n dividual - 2
represented that Renegade was a broker who could get money to
Individual - 2 abroad faster .
e.
As a result of the representations made by
Ind i vidual - 2 , Victim- 7 obtained and sent a cashier ' s check in
the amount of approximately $35 , 000 to Renegade on or about June
4 , 2019 .
In addition , on or about July 15 , 2019 , Victim- 7
initiated a wire transfer of approximate l y $9 , 550 to an account
in the name of Renegade (" Renegade Account - 1 " ) at a bank
headquartered in Atlanta , Georgia (" Bank- 4" ) .
f.
Individual - 2 .

Victim- 7 never received any money from

22 . Based on my rev i ew of ba n k records for Renegade
Account - 1 and a second account in the name of Renegade
(" Renegade Account-2 " ) at Bank- 4 , I have lea r ned the following ,
in substance and in part :
a.
On or about June 5 , 2019 , a cashier ' s check in
the amount of approximately $35 , 000 from Victim- 7 was deposited
into Renegade Account - 1 . Two days later , Renegade Account - 1
transferred (i) approximately $15 , 833 to a personal account in
the name of a JOSEPH IORHEMBA ASAN JR ., the defendant ; and (ii)
approximately $17 , 485 to a personal account in the name of
ASAN ' s mother .
On or about July 16 , 2019 , Renegade Account- 2
b.
received a deposit of approximately $9 , 550 from Victim- 7 .
23 . Based on my review of bank records for four bank
accounts in the name of Uxbridge (Uxbridge Account -1, Uxbridge
Account - 2 , Uxbridge Account - 3 , and " Uxbridge Account - 4 ",
collectively , the " Uxbridge Accounts " ) at four different banks ,
I have learned the · following , in substance and in part :
a.
JOSEPH IORHEMBA ASAN JR. , the defendant , was the
sole beneficial owner and signatory on the Uxbridge Accounts .

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b.
The address for ASAN and Uxbridge provided in
connection with the opening of the Uxbridge Accounts was the
Carteret Address .
The phone number for Uxbridge and ASAN provided
c.
by ASAN in connection with the opening of the Uxbridge Accounts
was the Asan Phone Number .
d.
Uxbr i dge Account - 1 was a business account opened
at Bank- 1 in the name of Uxbridge in or about September 2018 . A
business services membershi p application submitted to Bank-1 by
ASAN stated , among other things , that Uxbridge is engaged in
" b u ying and flipping homes , security and tech consulting ."
e.
Uxbridge Account - 2 was a business account opened
at Bank- 2 in the name of Uxbridge in or about July 2018 .
Account opening information provided by ASAN to Bank- 2 stated ,
among other things , that Uxbridge was involved in " purchasing
and investing in rea l estate wi thin the US .
. and abroad , to
countries such as Nigeria .
" A business deposit account
application for Uxbridge Account - 2 listed CHARLES I FEANYI OGOZY ,
the defendant , as an advisor for Uxbridge and an address in
Piscataway , New Jersey (the " Piscataway Address " ) for OGOZY .
Uxbridge Account-3 was a business account opened
f .
at Bank- 3 in the name of Uxbridge in or abou t September 20 1 8 .
Account opening information provided by ASAN to Bank- 3 stated ,
in substance and in part , t h at Uxbridge was i nvolved in real
estate and foreign investment , that the purpose of Uxbridge
Account - 3 wou l d be " genera l operating funds " and the primary
source of funding would be wires , and that ASAN was a U. S . Army
employee .
g.
Uxbridge Account - 4 was a business account opened
at a bank headquarte r ed in New Jersey (" Bank- 5 " ) in the name of
Uxbridge in or about September 2018. A certificate of formation
for Uxbridge provided to Bank- 5 stated , a mong other things , t h at
Uxbridge was formed on or about July 30 , 2018 and that its
business purpose is " real estate , foreign investment and stock
option consultancy ."
h.
Between at least in or about August 2018 and at
least in or about May 2019 , the Uxbridge Accounts had deposits
greater than approximately $500 that totaled approximately $1 . 36
million and withdrawals greater than approximately $500 that
totaled approximately $1 . 34 million. A majority of the deposits
in the Uxbridge Accounts consisted of large wire transfers from
various individuals and businesses or cash deposits , and many Qt
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the withdrawals consisted of transfers to other accounts under
the control of ASAN and OGOZY .
In total , the Uxbridge Accounts
transferred approximately $61 , 100 to accounts in the name of
OGOZY .
24 . Based on my review of bank records for five bank
accounts in the name of Renegade (Renegade Account - 1 , Renegade
Account - 2 , "Renegade Account - 3 ," " Renegade Account - 4 ," and
" Renegade Account - 5 ," collectively , the "Renegade Accounts " ) at
four different banks , I have learned the following , in substance
and in part :
a . JOSEPH IORHEMBA ASAN JR. , the defendant , was the
sole beneficial owner and signatory on the Renegade Accounts .
b. The address for Renegade provided in connection
with the opening of Renegade Account - 1 , Renegade Account - 2 , and
Renegade Account-4 was the Daytona Beach Address.
The address
for Renegade provided in connection with the opening of Renegade
Account - 3 and Renegade Account - 5 was an address in Miami ,
Florida (the "Renegade Miami Address " ) .
c.
The phone number for Renegade and ASAN provided
by ASAN in connection with the opening of the Renegade Accounts
was the Asan Phone Number .
d.
Renegade Account-1 and Renegade Account-2 were
business accounts opened at Bank- 4 in the name of Renegade in or
about February 2019 .
e.
Renegade Account - 3 was a business account opened
at Bank- 1 in the name of Renegade in or about January 2019 . A
business services membership application submitted to Bank- 1 by
ASAN stated , among other things , that Renegade is engaged in
" procurement and shipment of client goods worldwide ." In a
recorded phone call to Bank- 1 in connection with the opening of
Renegade Account - 3 , ASAN stated , in substance and in part , that
Renegade is a logistics company through which he procures and
moves a wide variety of goods for clients , and ASAN described
himself as a " jack of all trades ."
f .
Renegade Account - 4 was a business account opened
at a bank headquartered in Ohio ("Bank-6") in the name of
Renegade in or about February 2019 .
g.
Renegade Account-5 was a business account opened
at a bank headquartered in Massachusetts \ " Bank-7 " ) in th~ n~rne
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of Renegade in or about January 2019.
The nature of business
provided to Bank-7 for Renegade was " general freight trucking ."
h.
Between at least in or about January 2019 and at
least in or about September 2019 , the Renegade Accounts had
deposits greater than approximately $500 that totaled
approximately $1 . 63 million and withdrawals greater than
approximate l y $500 that totaled approximately $1 . 32 million . A
majority of the deposits in the Renegade Accounts consisted of
large wire transfers from various individuals and businesses or
cash deposits , and many of the withdrawals consisted of
transfers to other accounts under the control of ASAN and
CHARLES IFEANYI OGOZY , the defendant .
In total , the Renegade
Accounts transferred approximately $15 , 900 to accounts in the
name of OGOZY.
25 . Based on my review of bank records for a bank account
(the "Eldadoc Account " ) in the name of Eldadoc Consulting LLC
(" Eldadoc " ) at a bank headquartered in New Jersey (" Bank- 8 " ) , I
have lear n ed the following , in substance and in part :
The Eldadoc Account was a business account opened
a.
at Bank-8 in the name of El dadoc in or about January 2018 .
b.
JOSEPH IORHEMBA ASAN JR . and CHARLES IFEANYI
OGOZY , the defendants , were the sole signatories on the Eldadoc
Account .
c.
Account opening information provided to Bank- 8
stated , among other things , that OGOZY was the primary contact
for Eldadoc and that Eldadoc ' s line of business was " public
relations agencies ."
d.
The address for Eldadoc provided to Bank- 8 was
the Carteret Address .
e.
The business phone number for Eldadoc provided to
Bank- 8 was the Ogozy Phone Number .
Between at least in or about February 2018 and at
f .
least in or about May 2018 , the Eldadoc Account had deposits
greater than approximately $500 that totaled approximately
$298 , 000 and withdrawals greater than approximately $500 that
totaled approximately $285 , 000 . A majority of the deposits in
the Eldadoc Account consisted of large wire transfers from
various individuals and businesses or cash deposits , and many of

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the withdrawals consisted of transfers to other accounts under
the control of ASAN and OGOZY and third parties .
26 . Based on my review of bank records for five bank
accounts (collectively , the " Asan Accounts " ) in the name of
JOSEPH IORHEMBA ASAN JR ., the defendant , at four different
banks , including Bank- 1 , I have learned the following , in
substance and in part :
a.
ASAN was the sole beneficial owner and signatory
of the Asan Accounts.
b.
The addresses for ASAN provided for the Asan
Accounts included the Carteret Address , the Piscataway Address ,
and the Daytona Beach Address .
c.
The phone number provided in connection with the
opening of the Asan Accounts was the Asan Phone Number.
d.
Between at least in or about November 2017 and at
least in or about March 2019 , the Asan Accounts had deposits
greater than approximately $500 that totaled approximately
$550 , 000 and withdrawals greater than approximately $500 that
totaled approximately $516 , 000 . A majority of the deposits and
withdrawals in the Asan Accounts consisted of transfers to and
from accounts in the name of Uxbridge , Renegade , and CHARLES
IFEANYI OGOZY , the defendant , as well as other of the Asan
Accounts .
In total , the Asan Accounts transferred approximately
$87 , 500 to accounts in the name of OGOZY and received
approximately $22 , 000 in transfers from accounts in the name of
OGOZY .
27 . Based on my review of bank records for two bank
accounts in the name of CHARLES IFEANYI OGOZY , the defendant
(collectively , the " Ogozy Accounts") at two different banks ,
including Bank- 1 , I have learned the following , in substance and
in part :
a.
OGOZY was the sole beneficial owner and signatory
of the Ogozy Accounts.
b.
The addresses for OGOZY provided to the banks for
the OGOZY Accounts included , among other addresses , the Carteret
Address and the West Chester Address .
c.
The phone number provided by OGOZY in connection
with the opening of the Ogozy Accounts was the Ogozy Phone
Number .
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 Case 1:20-cr-00086-KMW Document 1 Filed 10/29/19 Page 14 of 16

d.
Between at least in or about March 2018 and at
least in or about April 2019 , the Ogozy Accounts had deposits
greater than approximately $500 that totaled approx i mately
$354 , 000 and withdrawa l s greater than approximately $500 that
totaled approximately $223 , 000 .
In total , accounts in the name
of OGOZY received approximately $164 , 000 in transfers from
accounts in the name of Uxbridge , Renegade , and JOSEPH IORHEMBA
ASAN JR ., the defendant .
28 . Based on my review of a September 29 , 2018 recorded
phone call made to a representative of Bank- 1 , I have learned
the following , in substance and in part :
a.

The phone call was made from the Ogozy Phone

Number .
The male i ndividual who made the call identified
b.
himself as JOSEPH IORHEMBA ASAN JR ., the defendant , and stated ,
in substance and in part , that he was calling about his business
account, Uxbridge Account - 1 .
In order to access i nformation regarding Uxbridge
c.
Account - 1 , the male individual who made the call provided the
las t four numbers of ASAN ' s social security number and ASAN ' s
date of birth to the Bank- 1 representative , but could not
provide the " code word " for the account or the last six digits
of the debit card associated with Uxbridge Account - 1 .
d.
Based on the circumstances of the call described
above and records from Bank- 1 establishing that CHARLES IFEANYI
OGOZY , the defendant , regu l arly made calls to Bank- 1 using the
Ogozy Phone Number when OGOZY inquired about his personal
account at Bank- 1 , I believe that OGOZY made the September 29 ,
2018 call to Bank- 1 purporting to be ASAN .
29 . Based on my review of a March 13 , 2019 recorded phone
call made by JOSEPH IORHEMBA ASAN JR ., the defendant , to a
representative of Bank- 1 inquiring why his accounts at Bank- 1 ,
namely Uxbridge Account - 1 , Renegade Account - 3 , and a personal
account , were frozen due to indicators of fraudulent activity , I
have learned that ASAN stated the following , in substance and in
part :
a.
ASAN owns two business accounts and a personal
account at Bank-1 .

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 Case 1:20-cr-00086-KMW Document 1 Filed 10/29/19 Page 15 of 16

b.
ASAN uses the Uxbridge account to collect
payments for advisory services he performed .
ASAN uses the other business account , namely
c.
Renegade Account - 3 , for a logistics company in order to procure
goods for clients and receive wire payments .
d.
One of the wires ASAN received was " kind of
fraudulent " because that wire did not come from where ASAN
expected it would come from , which ASAN realized " after the
fact ."
e.
ASAN sent a payment for a car to " Charles Ogozy "
whose account was also blocked . Ogozy was ASAN ' s roommate for
over a year and they were buddies in the U. S . Army .
30 .
Based on my review of recorded phone calls made by
CHARLES IFEANYI OGOZY , the defendant , from the Ogozy Phone
Number between March 12 and April 1 , 2019 to representatives of
Bank-1 inquiring why his personal account at Bank- 1 was frozen
due to indicators of fraudulent activity , I have learned the
following , in substance and in part :
In connection with an inquiry from a Bank- 1
a.
representative regarding transfers OGOZY sent and received from
JOSEPH IORHEMBA ASAN JR ., the defendant , OGOZY stated , in
substance and in part , that OGOZY and ASAN used to live together
and that OGOZY sold ASAN a car .
OGOZY was aware that ASAN had recently spoken to
b.
Bank-1 regarding ASAN ' s frozen accounts and that ASAN had told
Bank- 1 that everything was fine .
In connection with a discussion regarding the
c.
amount of time Bank- 1 needed to investigate OGOZY ' s account ,
OGOZY represented himself to be "an AML professional ," which I
believe is a reference to his purported experience in anti - money
laundering , and OGOZY stated , in substance and in part , that he
had never seen an investigation take so long .
OGOZY does not have any employment apart from his
d.
work with the military .
31 . Based on my training and experience , my participation
in this investigation , and my conversations with other law
enforcement agents and others , I know that the deposits of Bank2 through Bank- 8 were insured bl the FDIC at all relevant tim~~.
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 Case 1:20-cr-00086-KMW Document 1 Filed 10/29/19 Page 16 of 16

32.
Based on my review of flight records , I have learned
that JOSEPH IORHEMBA ASAN JR. and CHARLES IFEANYI OGOZY , the
defendants , both traveled from different locations in the United
States to St . Maarten in the Caribbean Sea on or about August
16 , 2019 and returned on the same flight to Atlanta , Georgia on
or about August 19 , 2019.
WHEREFORE , I respectfully request that warrants be issued
for the arrests of JOSEPH IORHEMBA ASAN JR . and CHARLES IFEANYI
OGOZY , the defendants , and that they be arrested and imprisoned
or bailed , as the case may be .

VINCENT Q. LAI
Special Agent
Federal Bureau of Investigation

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