Case Document 21-1 Filed 05/20/20 Page 1 of 18 EXHIBIT 1 Case Document 21-1 Filed 05/20/20 Page 2 of 18 Magistrate Judge Michelle L. Peterson CERTIFED TRUE COPY ATTEST: WILLIAM M. MCCOOL Clerk, District Court Western District of Washington By Deputy Clerk UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE UNITED STATES OF AMERICA, N0 :g Plaintiff COMPLAINT V. DENYS Title 18, United States Code, Sections 371, aka ?Denys Olegovich Iarrnak,? 1029(ax3)? and 2. aka ?Denis Jarmak,? aka ?Denys Olehovych Yarrnak,? aka ?gaktus,? aka ?gaktusOl,? aka ?denisj armak,? Defendant. - Filed Under Seal BEFORE the Honorable Michelle L. Peterson, United States Magistrate Judge, United States Courthouse, Seattle, Washington. The undersigned complainant being duly sworn states: COUNT 1 (Conspiracy to Commit Computer Fraud and Abuse) I. OFFENSE 1. Beginning at a time unknown, but no later than September 2015, and continuing through on or about November 20, 2019, Within the Western District of UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553?7970 1 United States v. Denys Iarmak Case Document 21-1 Filed 05/20/20 Page 3 of 18 Washington, and elsewhere, the defendant, DENYS IARMAK, and others known and unknown, did knowingly and willfully combine, conspire, confederate and agree together to commit offenses against the United States, to wit: a. to knowingly and with intent to defraud, access a protected computer without authorization and exceed authorized access to a protected computer, and by means of such conduct further the intended fraud and obtain anything of value exceeding $5,000.00 in any 1-year period, in violation of Title 18, United States Code, Sections 1030(a)(4) and and b. to knowingly cause thetransinission of a program, information, code, and command, and as a result of such conduct, intentionally cause damage without authorization to a protected computer, and cause loss to one or more persons during a 1? year period aggregating at least $5,000.00 in value and damage affecting 10 or more protected computers during a l-year period, in violation of Title 18, United States Code, Sections 1030(a)(5)(A) and II. OBJECTIVES OF THE CONSPIRACY 2. The objectives of the conspiracy included hacking into protected computer networks using malware designed to provide the conspirators with unauthorized access to, and control of, victim computer systems. The objectives of the conspiracy further included conducting surveillance of victim computer networks and installing additional malware on the victim computer networks for the purposes of establishing persistence, and stealing payment card track data, ?nancial information, and proprietary, private, and non-public inforr'nation, with the intention of using and selling such stolen items, either directly or indirectly, for ?nancial gain. The objectives of the conspiracy further included installing malware that would integrate victim computers into a botnet that allowed the conspiracy to control, alter, and damage compromised computers. MANNER AND MEANS OF THE CONSPIRACY 3 The manner and means used to accomplish the conspiracy included the following: COMPLAINT- 2 UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 5534970 United States v. Denys Iarmak Case Document 21-1 Filed 05/20/20 Page 4 of 18 a. The conspiracy developed and employed various malware designed to in?ltrate, compromise, and gain control of the computer systems of victim companies operating in the United States and elsewhere, including within the Western District of Washington. The conspiracy established and operated an infrastructure of servers, located in various countries, through which members coordinated activity to further the scheme. This infrastructure included, but was not limited to, the use of command and control servers, accessed through custom botnet control panels, that communicated with and controlled compromised computer systems of victim companies. b. . The conspiracy targeted victims in the Western District of Washington, and elsewhere, using, among other things, phishing techniques to distribute malware designed to gain unauthorized access to, take control of, and ex?ltrate data from the computer systems of various businesses. The conspiracy typically initiated its attacks by delivering, directly and through intermediaries, a phishing email with an'attached malicious ?le, using wires in interstate and foreign commerce, to an employee of the targeted victim company. The attached malicious file was embedded malware. The phishing email, through false representations and pretenses, fraudulently induced the recipient to open the attachment and click on the file to unwittingly activate the malware. c. If the recipient activated the malware, the computer on which it was opened would become infected and connect to one or more command and control servers controlled by conspiracy to report details of the newly infected computer and download additional malware. The command and control infrastructure relied upon various servers in multiple countries, including, but not limited to, the United States. (1. The conspiracy typically would install additional malware to establish remote control of the Victim computer. Once a victim?s computer was compromised, the conspiracy would incorporate the compromised machine or ?bot? into a botnet. e. The conspiracy used its access to the victim?s computer network and information gleaned from surveillance of the victim?s computer systems to install UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553-7970 3 United States v. Denys Iarmak mqom?bwmwoongazas:5 Case Document 21-1 Filed 05/20/20 Page 5 of 18 additional malware designed to target and extract particular information and property of value, including payment card data and proprietary and non?public information. f. The conspiracy frequently targeted payment cards used at the victim companies by customers making legitimate point-of-sale (POS) purchases. In those cases, the conspiracy configured malware to extract, copy, and compile the payment card data, and then to transmit the data from the victim computer systems to servers controlled by conspiracy. g. The conspiracy then monetized that stolen payment card data by, among other things, offering the payment card data for sale on various websites dedicated to such carding activity. IV. OVERT ACTS 4. In furtherance of the conspiracy, and to achieve the objects thereof, the defendants, and others known and unknown, did commit and cause .to be committed, the following overt acts, among others, in the Western District of Washington and elsewhere: a. On or about August 8, 2016, the conspiracy sent multiple phishing emails, containing a file embedded with malware, to an employee of the Emerald Queen Hotel and Casino (EQC), a federally recognized Native American Tribe with locations in Pierce County, Within the Western District of Washington. b. - Between on or about March 24, 2017, and April 18, 2017, the conspiracy harvested payment card data from point?of?sale devices from Chipotle Mexican Grill, including dozens of locations in the Western District of Washington. . c. On or about April 28, 2017, DENYS IARMAK commimicated with another member of the conspiracy in furtherance of the hacking activity, including . discussing the creation and use of phishing emails. - d. On or about on July 24, 2017, DENYS IARMAK and another member of the conspiracy discussed information stolen from a victim company. UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553?7970 4 United States v. Denys Iarmak Case Document 21-1 Filed 05/20/20 Page ?6 of 18 c. On or about October 27, 2017, DENYS IARIVIAK and another member of the conspiracy discussed information about the compromised computer system of a victim company, All in violation of Title 18, United States Code, Section 371. COUNT 2 (Access Device Fraud) 5. The allegations set forth in above paragraphs are re?alleged and incorporated as if fully set forth herein. 6. Beginning at a time unknown, and continuing through on or about November 20, 2019, within the Western District of Washington, and elsewhere, the defendant, DENYS IARMAK, and others known and unknown, knowingly and with intent to defraud, possessed ?fteen or more counterfeit and unauthorized access devices, namely, payment card data, account numbers, and other means of account access that can be used, alone and in conjunction with another access device, to obtain money, goods, services, and any other thing of value, and that can be used to initiate a transfer of funds, and aided and abetted such conduct; said activity affecting interstate and foreign commerce. All in violation of Title 18, United States Code, Sections 1029(a)(3), 1029(b)(l), 1029(c)(1)(A), and 2. And the complainant states that this Complaint is based on the following information: I, Briana L. Neumiller, being ?rst duly sworn on oath, depose and say: I. INTRODUCTION AND AGENT BACKGROUND 1 7. I am a Special Agent with the Federal Bureau of Investigation (FBI), and have been since 2009. I am assigned to the Cyber squad Where I investigate computer intrusions. My experience as an FBI Agent includes the investigation of cases involving the use of computers and the Internet to commit crimes. I have received training and UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553?7970 COMPLAINT- 5 United States v. Denys Iarmak Case Document 21-1 Filed 05/20/20 Page 7 of 18 gained experience in interviewing and interrogation techniques, arrest procedures, search Warrant applications, the execution of searches and seizures, Cybercrimes, computer evidence identi?cation, computer evidence seizure and processing, and various other criminal laws and procedures. I have participated personally in the execution of search warrants involving the search and seizure of computer equipment. I 8. As set forth herein, I submit that probable cause exists to establish that the defendant, DENYS IARMAK, knowingly and intentionally participated in a scheme to hack the protected computer networks of various victim entities and steal payment card data and information, which constitute unauthorized ?access devices,? in violation of federal law, to include Conspiracy to Commit Computer Fraud and Abuse, in violation of Title 18, United States Code, Section 371, and Access Device Fraud, in' violation of Title 18, United States Code, Sections 1029(a)(3), 1029(b)(1), 1029(c)(l)(A), and 2. Accordingly, I seek the issuance of an arrest warrant for IARMAK. 9. The facts set forth in this Af?davit are based on my own personal knowledge; knowledge obtained from other individuals during my participation in this investigation, including other law enforcement personnel and computer scientists; review of documents and records related to this investigation; communications with others who have personal knowledge of the events and circumstances described herein; and information gained through my training and experience. Because this Af?davit is submitted for the limited purpose, it does not set forth each and every fact that I or others have learned during the course of this investigation. 11. SUMMARY on PROBABLE CAUSE A. Background 10. US. authorities are investigating a transnational cybercriminal group engaged in a hacking and fraud scheme. Since at least September 2015, and continuing to the present, the group has attacked the protected computer networks of hundreds of businesses with the goal of infecting computer systems with malicious software (or, ?malware?) that allows the group to access and steal non?public information, such as 6 UNITED STATES ATTORNEY - 700 STEWART STREET, SUITE 5220 United States v. Denys Iarmak SEATTLE, WASHINGTON 98m} (206) 5534970 Case Document 21-1 Filed 05/20/20 Page 8 of 18 customer payment card data. Based on the initial estimates, this hacking scheme has stolen tens of millions of payment card numbers and has caused over 100 million dollars (U.S.) in losses to US. ?nancial institutions and companies. 11. systems of businesses, primarily in the restaurant, gaming, and hospitality industries, The hacking group generally, but not exclusively, targeted computer including numerous con?rmed victims located in the Western District of Washington. For instance, con?rmed victims of the hacking group who have publically acknowledged being attacked include numerous restaurant chains, such as Chipotle Mexican Grill, including multiple store locations within the Western Washington. For example, between approximately March 24, 2017, and April 18, 2017, the group, having successfully breached the protected systems of numerous Chipotle restaurant locations, harvested payment card data from point-of-sale devices, including dozens of locations in the Western District of Washington. 12. The group also targeted the Emerald Queen Hotel and Casino (EQC), a hotel and casino owned and operated by a federally recognized Native American Tribe with locations in Pierce County, within the Western District of Washington. For instance, on or about August 8, 2016, the group, either directly or through intermediaries, sent multiple phishing emails, containing a ?le embedded with malware, to an employee of EQC. 13. Credit cards compromised through the group?s proli?c hacking activity affected accounts held at dozens of federally insured ?nancial institutions and credit unions, including, among others, BECU, a credit union headquartered in the Western District of Washington. For example, on or about March 10, 2017, stolen card data related to accounts held at BECU, compromised through the computer network intrusion of a. con?rmed victim of this hacking group, was used to make unauthorized purchases at a merchant in Puyallup, ?Washington. UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553-7970 COMPLAINT- 7 United States v. Denys Iarmak asaasacaoeasaazaczs Case Document 21-1 Filed 05/20/20 Page 9 of 18 The Hacking Group?s Attack Methodology 14. The hacking group generally has targeted restaurants, hotels, and other businesses that engage in high volumes of point-of?sale payment card transactions. Generally, the hacking group attacks victim companies with phishingI emails that have attachments that either contain malware or link to malware. The phishing campaign will often involve a call to the recipient of a phishing email and the use of social engineering techniques to encourage the recipient to open the attachment and activate the group?s malware. 15. For example, as part of a phishing campaign, a member or'affiliate of the hacking group may call a hotel?s customer serVice representative under the pretense of being a customer who wants to make a reservation. The caller will claim falsely that the details of the reservation request can be found in a ?le attached to an email previously sent by the caller. If the employee opens the attachment and activates the embedded malware, the computer on which it was opened will become infected and connect to the hacking group?s command and control servers to report details of the newly infected computer and to download additional-malware. The additional malware will run automatically and will connect to additional servers used by the scheme to establish remote control of the infected computer. 16. After gaining access to a victim?s computer, the hacking group will deploy a wide variety of malware tools to conduct surveillance, control infected computers, and steal data. One of the hacking group?s primary goals is to target point-of-?gsale systems 1Phishing is a technique in which the perpetrators use email messages and/or fake websites to trick people into'providing information, such as network credentials user names and passwords) that may later be used to gain access to the victim?s systems. Phishing often utilizes social engineering techniques similar to traditional con?artist techniques in order to trick victims into believing they are providing their information to a trusted vendor or other acquaintance. Phishing emails are also often used to trick .a victim into clicking on documents or links that contain malicious software that will compromise the Victim?s computer system. 8 United States v. Denys I armak UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98 i 01 (206) 553-7970 Case Document 21-1 Filed 05/20/20 Page 10 of 18 that process high volumes of payment card transactions. Once the hacking group locates a point-of?sale system, it will use malware to capture and steal payment card data. The stolen data will then be sold on various criminal underground forums or through private sales. 17. The hacking group remains extremely active. The hacking group continues to launch extensive phishing attacks and steal point-of?sale information from businesses, such as fast food restaurants, that process a large volume of point-of?sale transactions. Additional phishing campaigns also indicate-that the hacking group has expanded its reach, and is now attacking victims such as law firms and other service providers with access to customer lists or con?dential financial information. The Hacking Group?s Use of a Virtual Work Environment 1.8. The hacking group does not have a central office or work location. Instead, the hacking group uses a distributed work force that relies on a secure, virtual work environment to coordinate its illegal activity. This virtual work environment allows members in different cities and countries to remotely attack, access, and control victim computers in an organized fashion. This virtual work environment also allows the hacking group to control who can access the work environment, thereby protecting the group?s illegal activity. 19. One component of the virtual work environment is an elaborate network of servers located throughout the world that the hacking group uses as part of its command and control infrastructure. US. authorities have identi?ed and examined a number of these command and control servers. This examination revealed that the servers are used to host control panels that allow the hacking group to remotely access and control compromised victim computers. Log data and intercepted communications demonstrated that members of the hacking group routinely access the Control panels from their residences. 20. communication servers located throughout the world that the hacking group uses to UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 9810} (206) 553-7970 Another component of the virtual work environment is a number of 9 United States v. Denys Iarmak Case Document 21-1 Filed 05/20/20 Page 11 of 18 facilitate the malware scheme. US. authorities have identi?ed and?examined a number of these servers. This examination demonstrated that the servers provide the hacking group with both secure channels of communication and virtual platforms on which they coordinate their attacks against victim companies even though each member is working from a remote location. For example, in approximately August 2017, foreign law enforcement provided US. authorities with a forensic image of a physical server used by the hacking group (hereinafter, Analysis of the image showed that Server?l contained numerous virtual communication servers, including a private Jabber server that permitted members of the hacking group to have communications about their illegal activity. Jabber is an instant messaging service that allows members to send communications through a public or private server. In order to have an account within a private Jabber server, an administrator of the server must create an account for the user. I 2 US. authorities to identify many members of the hacking group and their roles in the Examination of the hacking group?s Jabber communications has allowed illegal enterprise. Although members of the hacking group generally used aliases and concealed their true names from? each other, members regularly provided identifying information in Jabber communications with certain high-level members of the group to receive payment for their participation in the scheme. This information included information such as true names, addresses, bank account information, and information to receive digital currency or money order transfers. 22. instant messaging, and ?le?sharing program. Examination of the HipChat servers Server-l also contained virtual HipChat servers. HipChat is a group chat, showed that the hacking group used HipChat to coordinate their efforts to breach the network securities 'of victim companies, to share stolen data such as payment card information, and to interview and recruit new members. 23. Through this investigation, which has included review of evidence obtained from foreign authorities, US. authorities obtained and examined a forensic image of UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553-7970 COMPLAINT- 10 United States v. Denys Iarmak Case Document 21-1 Filed 05/20/20 Page 12 of 18 another physical server used by hacking group (hereinafter, ?Server-2?) in approximately November 2017. Like Server-l, Server-2 contained numerous virtual communication servers used to facilitate the malware scheme. Both Server-l and Server?2 contained virtual IRA servers. IRA is a project management and issue?tracking program commonly used by software development teams. JIRA allows team members to create ?projects? containing posted ?issues? under which other team members can make comments and share data. This feature thereby facilitates collaboration between team members who may be working from different locations or during different hours. 24. hacking group used the JIRA servers to collaborate on their efforts to breach and steal Examination of Server?l and Server?2 revealed that members of the data from victim companies. Often, hacking group members would create ?issues? in JIRA with names that referenced a particular victim. Under each IRA ?issue?, members would track?their progress breaching the victim?s security, upload data stolen from the victim, and provide guidance to each other. The JIRA servers logged activity related to an ?issue? and tracked a variety of information including the user who created the ?issue?, users who commented under or uploaded ?les under the ?issue?, and users who otherwise had access to the ?issue?. This information has allowed investigators to link members to attacks against speci?c victims. 25. that the group?s virtual work environment allowed the members of the group to work The hacking group?s Jabber, HipChat, and JIRA communications con?rm together closely even though the members were working from computers at their residences or from their mobile devices. In numerous conversations, members of the hacking group made reference to working at home or the need to go offline in order to run domestic errands such as going to the doctor?s office. Notably, members of the hacking group were required to work late at night in order carry out malicious activity, such as sending phishing emails, during the business hours of victim companies who were located several time zones away. UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 5534970 11 United States v. Denys Iarmak mummnmeoESSE?L?EE3533 Case Document 21-1 Filed 05/20/20 Page 13 of 18 Examination of Devices Belonging to Members of the Hacking Group 26. members of the hacking group indicates that members of the hacking group keep The U.S. authorities? examination of devices belonging to individual extensive evidence of their illegal activity on their personal computers and mobile devices, including data that is exchanged through the hacking group?s virtual work environment. For example, U.S. authorities examined a laptop seized by foreign authorities from the home of a member of the hacking group. The laptop contained many of the malware too1s used by the hacking group in addition to credentials to remotely access the hacking group?s servers. One of the malware tools was used over 1,200 times over the course of a 16-month period. Forensic examination of communications on the laptop indicate that the owner of the laptop was largely working from home when he developed phishing emails, attempted to breach victim computer systems, and stole data from compromised computers. In addition, the laptop had numerous folders, each dedicated to a speci?c victim, which contained data stOlen from that victim. This stolen data included addresses for internal victim servers, .login credentials (user name and password) for victim Servers, tax information, customer order information, and other non- public information. Most notably, the laptop contained a variety of stolen ?nancial information, including stolen credentials that could be used to access a victim?s online bank accounts and over 4,000 unique payment card numbers. The laptop also contained extensive communications with dozens of members of the hacking group, including over 80,000 Jabber messages. In certain of these communications, the user of the laptop requested money order transfers in return for work performed on behalf of the hacking group. 27. from a different member of the hacking group while he was on vacation in a foreign Through this investigation, U.S. authorities also examined a laptop taken country. As with the ?rst laptop, the second laptop contained extensive evidence of the malware scheme and information exchanged through the hacking group?s virtual workspace. For example, the second laptop contained malware tools, credentials to UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553-7970 12 United States v. Denys Iarm ak Case Document 21-1 Filed 05/20/20 Page 14 of 18 access the hacking group?s servers, data stolen from victims, and over 4,000 payment card numbers. The laptop also contained over 85,000 Jabber communications with other members of the hacking group in which the owner of the laptop discussed his efforts to breach victims? networks, shared stolen data, and requested payment in digital currency for his Work. Notably, the Jabber communications indicate that the hacking group was using a wide?variety of digital currency services or exchanges including, but not limited to, Binance, Electrum, and Monero. 28. also use mobile devices to facilitate the malware scheme. In addition to private Jabber, U.S. authorities have obtained evidence that members of the hacking group HipChat, and JIRA servers, the hacking group uses a variety of other communication services such as Mumble, Telegram, Threema and Viber. U.S. authorities have gathered evidence that members of the hacking scheme access these communication services from their mobile devices. For example, pursuant to a mutual legal assistance request, U.S. authorities examined a mobile phone taken from one of the previously mentioned hacking group members while he was on vacation. The mobile phone contained communications with other members of the hacking group regarding the group?s illegal activity, including Telegram, Threema, and Viber communications. B. I Denys Iarmak 29. U.S. authorities have identi?ed multiple members of the hacking group, including DENYS IARMAK, also known as Denys Olegovich Iarmak, Denis Jarmak, and Denys Olehovych Yarmak, a resident and citizen of Ukrainian. Since at least 2016, IARMAK, who used online aliases such as ?gaktus,? ?denisjarmak?, and ?gaktusOl? served as a hacker within the group and was involved in attacking multiple victim companies, including the successful hacks of several restaurant chains located in the United States. 30. work environment to collaborate and coordinate with other group members. For instance, As with other members of the hacking group, IARMAK used the virtual on July 24, 2017, IARMAK used Jabber to exchange stolen victim information with UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553-7970 13 United States v. Denys [arm ak Case Document 21-1 Filed 05/20/20 Page 15 of 18 another group member, edir Hladyr, charged in this (United States v. Hladyr, Furthermore, on March 3, 2017, IARMAK, using the alias ?gaktus,? updated a JIRA issue he had created for a speci?c victim company and uploaded data he had stolen from that US. company. IARMAK had access to approximately 25 JIRA issues on Server-1 and 20 JIRA issues on Server-2. 31. In a Jabber conversation between IARMAK and Hladyr on October 20, 2017, Hladyr provided user credentials for a compromised US. business. On October 27, 2017, IARMAK replied back to Hladyr with internal system information of compromised machines related to the US. business. Through this investigation, authorities have con?rmed that this hacking group stole payment card data from that US. business. 32. IARMAK frequently used the aliases ?denis.jarmak? and ?gaktus? when communicating with other members of the hacking group. For example, on December 24, 2016, in a Jabber communication between Hladyr and IARMAK (denis.j armak@j abber.ru), according to a machine translation, IARMAK told Hladyr to add him into a room and provided the name ?GakTus.? 33. Like other members of the group, IARMAK provided his true name in order to receive payment for his work in furtherance of the group. For example, in a December 26, 2016 Jabber chat with one of the leaders of the hacking group, IARMAK (denis. armak@j abber.ru) sent his PrivateB ank account number to receive salary payments. Further, through the investigation, authorities further identi?ed IARMAK through his email account. For instance, authorities identi?ed and later obtained a search warrant for personal email account which Was linked to the PGP public key IARMAK used to have communications with other group members in furtherance of the coordinated hacking activities. According to records obtained from Google, the subscriber for this email account is Denis Jarmak. This email account contained photos of Ukrainian passports and other identi?cation documents. According to this and other documentation,? IARMAK is believed to UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 9810] (206) 553-7970 United States v. Denys Iarmak . Case Document 21-1 Filed 05/20/20 Page 16 of 18 currently reside in Kyiv, Ukraine. The passport listed date of birth as The email account also contained a copy of resume (which, acCording to a machine transliteration, was in the name Denys Olegovych Yarmak), with the same date of birth, and listed his father?s, mother?s, and sister?s names, which was corroborated through other sources. resume listed work experience as a system administrator for multiple companies. The email account also contained a registration email for the aforementioned Jabber account (denis.j armak@jabber.ru) and account creation and security alerts for one of linked email accounts, gaktusO @gmail.com, among others. 34. IARMAK also used the email account denis.j armak@gmail.com in furtherance of the group?s scheme. For example, in early April 2017, IARMAK exchanged multiple messages with an Anti-Virus (AV) company related to activating an AV product. also forwarded copies of these emails two other known members of the hacking group. Through the investigation, authorities have determined that one of the techniques used by the group is to check their various malware against AV products disconnected from Internet. This technique allows the group to determine whether the malware is being detected by the AV product as malicious without providing a copy of the malware to the AV companies. 35. IARMAK and edorov, another known group member charged in this District (United States v. Fedorov, CR18-004RSM), IARMAK explained to Fedorov how to In a translated Jabber communication on April 28, 2017, between create the malware payload for a phishing document and referenced going into the machine with AV. IARMAK noted that a particular payload was detected by two AV companies, which meant that it was ?burned somewhere.? When Fedorov noted another tool used by the group that was tested against AV, IARMAK sought details on whether the testing was done with the interface to the Internet turned off. This conversation was consistent with the known methodology of the hacking group. UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553-7970 15 United States v. Denys Iarmak Case Document 21-1 Filed 05/20/20 Page 17 of 18 36. in that same conversation, IARMAK also discussed phishing emails and speci?cally advised that he usually replaced the default picture of the embedded file which deploys malware it?double clicked with some other image speci?c to the targeted company. As noted above, the investigation and security community reporting have obsewed that the phishing messages sent by this hacking group usually seek to manipulate targeted victims into double clicking on an image in the message attachment to activate malware and compromise machines on the victim network. 37. IARMAK also was implicated by other members of the hacking group. In STATES 700 STEWART STREET, Sum: 5220 WAsmNe'mN 98101 (206) 553-7970 COMPLAINT- 16 United States v. Denys Iarmak \oo?qoxmewwhn Case Document 21-1 Filed 05/20/20 Page 18 of 18 CONCLUSION 38. Based on the above facts, I respectfully submit that there is probable cause to believe that DENYS IARMAK did knowingly and intentionally committed the offenses of Conspiracy to Commit Computer Fraud and Abuse, in violation of Title 18, United States Code, section 371, and Access Device Fraud, in violation of Title 18, United States Code, Sections 1029(a)(3), 1029(b)(1), 1029(c)(1)(A), and 2. ?aw Briana L. Neumiller, Complainant Special Agent, Federal Bureau of Investigations Based on the Complaint and Af?davit sworn to before me, and subscribed in my 1 presence, the Court hereby ?nds that there is probable cause to believe the Defendant committed theoffenses set forth in the Complaint. Dated this day of November, 2019. MICHELLE L. PETERS ON United States Magistrate Judge UNITED STATES ATTORNEY 700 STEWART STREET, SUITE 5220 SEATTLE, WASHINGTON 98101 (206) 553-7970 17 United States v. Denys Iarmak