Case 1:20-cv-02228 Document 1 Filed 08/13/20 Page 1 of 22

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
155 VIRTUAL CURRENCY ASSETS
Defendants.

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Civil Action No. 20-cv-2228
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UNITED STATES’ VERIFIED COMPLAINT FOR FORFEITURE IN REM
COMES NOW, Plaintiff the United States of America, by and through the Acting United
States Attorney for the District of Columbia, and brings this Verified Complaint for Forfeiture in
Rem against the defendant properties, namely: 155 virtual currency accounts (the “Defendant
Properties”), which are further described in Attachment A. The United States alleges as follows
in accordance with Rule G(2) of the Federal Rules of Civil Procedure, Supplemental Rules for
Admiralty or Maritime Claims and Asset Forfeiture Actions.
NATURE OF ACTION AND THE DEFENDANT IN REM
1.

This in rem forfeiture action arises out of an investigation by the Internal Revenue

Service – Criminal Investigation’s Cyber Crimes Unit (“IRS-CI”), Federal Bureau of Investigation
(“FBI”), and Homeland Security Investigations (“HSI”). Specifically, the United States is
investigating the unlawful use of the cryptocurrency to support and finance terrorism.
2.

The Defendant Properties are subject to seizure and forfeiture pursuant to 18 U.S.C.

§ 981(a)(1)(G)(i), as foreign assets of designated foreign terrorist organizations based in Syria that
are linked to al-Qaeda, including the Al-Nusrah Front (“ANF”) and Hay’at Tahrir al-Sham
(“HTS”), which have engaged in planning and perpetrating federal crimes of terrorism as defined

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in 18 U.S.C. § 2332b(g)(5), against the United States, citizens or residents of the United States,
and as foreign assets affording any person a source of influence over any such entity or
organization.
JURISDICTION AND VENUE
3.

This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1345 and 1355.

4.

Venue is proper pursuant to 28 U.S.C. § 1355(b)(2).
FACTS GIVING RISE TO FORFEITURE

I.

BACKGROUND
A.

al-Qaeda and Affiliated Foreign Terrorist Organizations

5.

On October 8, 1999, the United States Secretary of State designated al-Qaeda as a

Foreign Terrorist Organization (“FTO”) under Section 219 of the Immigration and Nationality Act
and as a Specially Designated Global Terrorist (“SDGT”) under section 1(b) of Executive Order
13224. The Secretary of State also added the following aliases to the FTO listing: “the Base,” the
Islamic Army, the World Islamic Front for Jihad Against Jews and Crusaders, the Islamic Army
for the Liberation of the Holy Places, the Usama Bin Laden Network, the Usama Bin Laden
Organization, Islamic Salvation Foundation, and The Group for the Preservation of the Holy Sites.
To date, AQ remains a designated FTO.
6.

Al Qaeda’s designation as an FTO and SDGT has been renewed on multiple

occasions since 1999, and al-Qaeda remains a designated FTO and SDGT today.
7.

On October 15, 2004, the Secretary of State designated Jam’at al Tawhid wa’al-

Jihad as an FTO under Section 219 of the Immigration and Nationality Act and as a SDGT under
section 1(b) of Executive Order 13224.
8.

On December 15, 2004, the Deputy Secretary of State added numerous aliases to

the Jam’at al Tawhid wa’al-Jihad FTO designation including the alias al-Qaida in Iraq (“AQI”).

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9.

On December 11, 2012, the Secretary of State amended the FTO and SDGT

designations of Jam’at al Tawhid wa’al-Jihad to include the following aliases: al-Nusrah Front
(“ANF”), Jabhat al-Nusrah, Jabhet al-Nusra, The Victory Front, and Al-Nusrah Front for the
People of the Levant.
10.

On May 15, 2014, the Secretary of State, in response to the evolving nature of the

relationships between ANF and AQI, amended the FTO and SDGT designations of AQI to remove
all aliases associated with ANF. Separately, the Secretary of State then designated al-Nusrah Front
(ANF), also known as Jabhat al-Nusrah, also known as Jabhet al-Nusra, also known as The Victory
Front, also known as Al-Nusrah Front for the People of the Levant, also known as Al-Nusrah Front
in Lebanon, also known as Support Front for the People of the Levant, and also known as Jabaht
al-Nusra li-Ahl al-Sham min Mujahedi al-Sham fi Sahat al-Jihadb as an FTO under Section 219
of the Immigration and Nationality Act and as a SDGT under section 1(b) of Executive Order
13224.
11.

On October 19, 2016, the Secretary of State amended the FTO and SDGT

designations of ANF to include the following new aliases: Jabhat Fath al Sham, also known as
Jabhat Fath al-Sham, also known as Jabhat Fatah al-Sham, also known as Jabhat Fateh al-Sham,
also known as Fatah al-Sham Front, also known as Fateh Al-Sham Front, also known as Conquest
of the Levant Front, also known as The Front for liberation of al Sham, also known as Front for
the Conquest of Syria/the Levant, also known as Front for the Liberation of the Levant, also known
as Front for the Conquest of Syria.
12.

On May 17, 2018, the Secretary of State amended the FTO and SDGT designations

of ANF to include the following aliases: Hay’at Tahrir al-Sham, also known as Hay’et Tahrir alSham, also known as Hayat Tahrir al-Sham, also known as HTS, also known as Assembly for the
Liberation of Syria, also known as Assembly for Liberation of the Levant, also known as
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Liberation of al-Sham Commission, also known as Liberation of the Levant Organisation, also
known as Tahrir al-Sham, also known as Tahrir al-Sham Hay’at.
13.

To date, ANF and HTS remain designated FTOs.

B.

Bitcoin

14.

Bitcoin (“BTC”) is a decentralized virtual currency, which is supported by a peer-

to-peer network. All transactions are posted to a public ledger, called the Blockchain (which can
be seen at https://Blockchain.info). Although transactions are visible on the public ledger, each
transaction is only listed by a complex series of numbers that does not identify the individuals
involved in the transaction. This feature makes BTC pseudonymous; however, it is possible to
determine the identity of an individual involved in a BTC transaction through several different
tools that are available to law enforcement. For this reason, many criminal actors who use BTC
to facilitate illicit transactions online (e.g., to buy and sell drugs or other illegal items or services)
look for ways to make their transactions even more anonymous.
15.

A BTC address is a unique token; however, BTC is designed such that one person

may easily operate many BTC accounts. Like an e-mail address, a user can send and receive BTC
with others by sending BTC to a BTC address. People commonly have many different BTC
addresses and an individual could theoretically use a unique address for every transaction in which
they engage. A BTC user can also spend from multiple BTC addresses in one transaction;
however, to spend BTC held within a BTC address, the user must have a private key, which is
generated when the BTC address is created and shared only with the BTC-address key’s initiator.
Similar to a password, a private key is shared only with the BTC-address key’s initiator and ensures
secured access to the BTC. Consequently, only the holder of a private key for a BTC address can
spend BTC from the address. Although generally, the owners of BTC addresses are not known
unless the information is made public by the owner (for example, by posting the BTC address in
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an online forum or providing the BTC address to another user for a transaction), analyzing the
public transactions can sometimes lead to identifying both the owner of a BTC address and any
other accounts that the person or entity owns and controls.
16.

BTC is often transacted using a virtual-currency exchange, which is a virtual-

currency trading platform and bank. It typically allows trading between the U.S. dollar, other
foreign currencies, BTC, and other digital currencies. Many virtual-currency exchanges also act
like banks and store their customers’ BTC. Because these exchanges act like banks, they are
legally required to conduct due diligence of their customers and have anti-money laundering
checks in place. Virtual currency exchanges doing business in the United States are regulated
under the Bank Secrecy Act, codified at 31 U.S.C. § 5311 et seq., and must collect identifying
information of their customers and verify their clients’ identities.
B.

Blockchain Analysis

17.

While the identity of the BTC address owner is generally anonymous (unless the

owner opts to make the information publicly available), law enforcement can identify the owner
of a particular BTC address by analyzing the blockchain. The analysis can also reveal additional
addresses controlled by the same individual or entity. For example, a user or business may create
many BTC addresses to receive payments from different customers. When the user wants to
transact the BTC that it has received (for example, to exchange BTC for other currency or to use
BTC to purchase goods or services), it may group those addresses together to send a single
transaction. Law enforcement uses sophisticated, commercial services offered by several different
blockchain-analysis companies to investigate BTC transactions. These companies analyze the
blockchain and attempt to identify the individuals or groups involved in the BTC transactions.
Specifically, these companies create large databases that group BTC transactions into “clusters”
through analysis of data underlying BTC transactions.
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18.

Through numerous unrelated investigations, law enforcement has found the

information provided by these companies to be reliable. The third-party blockchain-analysis
software utilized in this case is an anti-money laundering software used by banks and law
enforcement organizations worldwide.

This third-party blockchain analysis software has

supported many investigations, and been the basis for numerous search and seizure warrants, and
as such, has been found to be reliable. Computer scientists have independently shown that they
can use “clustering” methods to take advantage of clues in how BTC is typically aggregated or
split up to identify BTC addresses and their respective account owners.
19.

Since the blockchain serves as a searchable public ledger of every BTC transaction,

investigators may trace transactions to BTC exchangers.

Because those exchanges collect

identifying information about their customers, subpoenas or other appropriate process submitted
to these exchangers can, in some instances, reveal the true identity of the individual responsible
for the transaction.
II.

AL-QAEDA BTC TERROR FINANCE CAMPAIGN
20.

In April 2019, the administrator of the Telegram group “Tawheed & Jihad Media,”

which is now defunct, provided a Bitcoin address starting with 37yrx7 (“Defendant Property
AQ1”) as a repository for pro-al-Qaeda donations.
21.

Posts on the Tawheed & Jihad Media Telegram group during that same time frame

advertised fundraising campaigns to raise money for fighters. For example, on or about May 25,
2019, a user posted an image with the text: “FUNDRAISING CAMPAIGN” and “FINANCE
BULLETS AND ROCKETS FOR THE MUJAHIDEEN.” Muhajideen in this context refers to al
Qaeda fighters or soldiers. The post accompanying the image stated, “For Donations and more
details: Please message: @TawheedJihadMedia.”

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22.

The media content of the Tawheed & Jihad Media Telegram group included

watermarked images of both Ansar al-Tawheed, a jihadist group that was created in or about March
2018, and the Syria-based pro-al-Qaeda collective Wa Haredh al-Moemeneen (“Incite the
Faithful”), of which Ansar al-Tawheed is a member. The collective Wa Haredh al-Moemeneen
was formed in approximately the fall of 2018 to oppose negotiations with the Syrian regime and,
as of May 2019, when the Telegram group administrator solicited donations to Defendant
Property AQ1, was fighting against Syrian government forces and their allies in northern Syria.
23.

On or about May 5, 2019, Defendant Property AQ1 sent its entire balance of BTC,

approximately 0.14610741 BTC, to a cluster of BTC addresses, containing the root address starting
with 3LcrD (“Defendant Property AQ2”).
24.

Al-Qaeda and affiliated terrorist groups have been operating a BTC money

laundering network using Telegram channels and other social media platforms to solicit BTC
donations to further their terrorist goals. As described below, al-Qaeda and affiliated terrorist
groups operate a number of Telegram channels and purport to act as charities when, in fact, they
are soliciting funds for the mujahedeen. Al-Qaeda and the affiliated terrorist groups are connected
and use multi-layered transactions to obfuscate the movement of BTC.
25.

Defendant Property AQ2 is a central hub used to collect funds and then

redistribute the funds within this money laundering network. From on or about February 25, 2019
through on or about February 5, 2020, Defendant Property AQ2 received approximately
15.27050803 BTC via 187 transactions.
26.

Between February 25 through on or about July 29, 2019, Defendant Property AQ2

sent approximately 9.10918723 BTC via 38 transactions to an account at a virtual currency
exchange (Defendant Property 1).
27.

Funds received by Defendant Property 1 were in turn sent to various online gift
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card exchanges (“GCE”) that facilitate the sale of various gift cards in exchange for
cryptocurrency. This is a common method of money laundering known to law enforcement.
28.

On or about May 21, 2019, a BTC address starting with 3KhAH (Defendant

Property 2) sent approximately 0.02825625 BTC to Defendant Property AQ2.
29.

On or about May 29 and 30, 2019, Defendant Property 2 sent a total of

approximately 0.07640859 BTC to a BTC address starting with 3LZg4 (Defendant Property 3).
Within hours, Defendant Property 3 sent BTC to Defendant Property AQ2. This is a common
method of money laundering known to law enforcement as layering.
Leave an Impact Before Departure
30.

A Syria-based organization that translates to “Leave an Impact Before Departure,”

has conducted donation campaigns asking people to send support via BTC. As of July 30, 2020,
Leave an Impact Before Departure publicly claimed that it was a charity conducting humanitarian
work. However, this group has posted images on its Telegram channel regarding the prices of
military equipment needed to support the fighters inside of Syria.

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31.

For example:

32.

As demonstrated above, these posts are seeking funds for military equipment.

33.

Leave an Impact Before Departure advertised an account at a virtual currency

exchange (Defendant Property 4) in the Telegram channel as its deposit address to which donors
could send BTC.
34.

Defendant Property 4 received approximately 14.58133728 BTC via 65

transactions for the period on or about March 10 to on or about December 11, 2019. This includes
seven transactions totaling approximately 0.73060999 BTC from Defendant Property AQ2.
35.

A cluster of approximately 29 BTC addresses with a root address starting with

1JtyZ received (Defendant Property 5 - Defendant Property 33) approximately 0.29328346
BTC via six transactions from Defendant Property AQ2. Cluster 1JtyZ sent:
a.

0.76916964 BTC via three transactions to Defendant Property 1; and

b.

0.2270076 BTC via two transactions to Defendant Property 4.

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Al Ikhwa
36.

The Telegram channel for @Al_ikhwa_official appeared online in or around June

2018. The administrator of the group is listed as “@AL_ikhwa.” The group’s profile describes
them as an “independent charity on the ground in Syria” and that they “do not support any acts of
terrorism;” however, blockchain analysis and a review of related social media posting
demonstrates otherwise.
37.

Many of Al Ikhwa’s posts on Telegram solicit donations through PayPal, Western

Union and “anonymous payment” with BTC. Their first post stated, in part:
…supporting the brothers in Syria, Wives of [martyrs] and their families…[and]
We help those who defend the Muslims in [Syria].
38.

The Al Ikhwa administrator posted 11 BTC addresses for potential donors to fund

(“Al Ikhwa Cluster”). These 11 BTC addresses represent Defendant Property 34 through
Defendant Property 44.
39.

Blockchain analysis revealed the Al Ikhwa Cluster has received approximately

0.43820188 BTC via 18 transactions for the period October 15, 2018 to September 3, 2019.
40.

Approximately half of the BTC received by this cluster, 0.22524884 BTC, was sent

via four transfers to Defendant Property AQ2.
41.

Shortly thereafter Defendant Property AQ2 received BTC from the Al Ikhwa

Cluster, the proceeds of which were sent to Defendant Property 1.
42.

Al Ikhwa also operated a Facebook account which had posted four BTC addresses

for donations. Two of these BTC addresses are part of the Al Ikhwa Cluster and the other two
are part of a cluster of six BTC addresses (“Al Ikhwa Facebook Cluster”). These six BTC
addresses represent Defendant Property 45 through Defendant Property 50. Al Ikhwa

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Facebook Cluster sent approximately 0.09413247 BTC during April and May 2020, via three
transfers to the Al Ikhwa Cluster.
43.

The documented practice of layering BTC transfers is observed herein, where Al

Ikhwa is attempting to obfuscate the source of BTC and conceal the identity of the owner.
44.

The Al Ikhwa administrator stated on Telegram:
Yeah, bitcoin makes a new one [i.e. address] every transaction so it’s good, it
always looks like it’s going to a different place..if you ever get [a] police visit and
they want to trap you to say you sent [donations] to Syria.. say they are
liars..because one person told me maybe they can’t track the bitcoin but they can
see IP address...But our Syria IP addresses are Turkish because our Internet comes
from Turkey. So if they try to trap someone and say you sent money here by
showing IP address, you say they are liars and you did business in Turkey.. cause
the IP address is Turkish.

45.

The Al Ikhwa money laundering network conducted layered transactions including

as follows:
a.

Al Ikhwa Cluster sent 0.09019068 BTC to cluster 3HvtR on or about

January 20, 2019, and then five days later this cluster sent 0.3372531 BTC to Defendant
Property 1.
b.

Al Ikhwa Cluster sent 0.05927279 BTC to address 36A2P on or about

April 2, 2019.
i. That same day, address 36A2P sent 0.041 BTC to Defendant Property 4;
ii. A few days later, address 36A2P sent 0.01953034 BTC to Defendant
Property 1;
c.

Al Ikhwa Cluster sent a total of 0.00016023 BTC via two transactions to

cluster 12Btp on or about October 19, 2018, and on or about March 2, 2019. On or about
July 16, 2019, cluster 12Btp sent 0.00651841 BTC to Defendant Property AQ2.

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Malhama Tactical
46.

Open source reporting has linked Al Ikhwa to Malhama Tactical, a jihadist military

company that trains HTS fighters and has solicited BTC to finance HTS operations in Syria.
47.

Malhama Tactical is described in open source materials as a “jihadist private

military company.” It is comprised of fighters from Uzbekistan and the Russian Caucuses.
48.

The Twitter page of Malhama Tactical’s founding leader, Abu Salman Belarus,

describes him as the “Commander of Malhama Tactical, we are the military instructors, we’ve
been teaching rebels how to fight and provide emergency aid on battlefield since 2013.” In a
published interview in February 2019, Abu Salman Belarus stated that Malhama Tactical worked
with and trained HTS fighters. Moreover, in around July 2019, Malhama Tactical fundraised for
drones to be used for “artillery adjustment and reconnaissance.” In releasing an intelligence report
about that fundraising effort, the SITE Intelligence Group described Malhama Tactical as an HTS
Special Forces training group.
49.

Notably, an April 2020 online video from a news media outlet showed interviews

with members of Malhama Tactical about certain military tactics they used after recent battles in
Idlib, Syria. In a published video interview on or about June 11, 2020, a Malhama Tactical leader
named Ali al-Shishani described Malhama Tactical as a group of professional instructors who
trained members of the Syrian resistance and stated that HTS was one of the groups with whom
Malhama Tactical worked.
50.

The Twitter account of Malhama Tactical’s founder, Abu Salman Belarus, tweeted

two BTC addresses when soliciting donations. His tweets stated, “You can support and help us
anonymously and safely with Bitcoin wallet: 1J5x4,” and “Bitcoin wallet for support instructor
team of [MT]: 1LVwt.”

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51.

These two Malhama Tactical addresses are part of a cluster of 23 addresses (“MT

cluster”) that received approximately 0.19501359 BTC via 15 transactions for the period July 13
to November 22, 2019. These 23 BTC addresses represent Defendant Property 51 through
Defendant Property 73.
52.

On or about October 9, 2018, MT cluster sent approximately 0.03839 BTC to

cluster 3Jb1M which has sent BTC to Defendant Property AQ2 on multiple occasions.
Reminders From Syria
53.

The Al Ikhwa Telegram channel forwarded

several posts from the

“@RemindersFromSyria” (“RFS”) channel, and the RFS channel has similarly forwarded Al
Ikhwa’s posts, many of which contained Al Ikhwa’s BTC addresses.
54.

RFS’s channel falsely states that they are “not affiliated with any fighting groups

in Syria” and they “do not promote any acts of violence and terrorism.” In fact, they have posted
numerous donation requests to support foreign fighters, threats to the United States, and radical
extremists abroad.
55.

For example, one post showed a photograph of a machine gun with a military-style

vest holding numerous additional magazines of bullets. Another post stated:

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56.

On or about July 16, 2020, an HSI agent acting in an undercover capacity (“UCA”)

messaged the administrator of the RFS Telegram channel asking to donate BTC. The administrator
provided a BTC address starting with 1CoEM (Defendant Property 74). Subsequently,
Defendant Property 74 clustered with Defendant Property 75 and Defendant Property 76
(“RFS Cluster”).
57.

The administrator stated that he hoped for the destruction of the United States and

warned the UCA to be careful of possible criminal consequences from carrying out a jihad in the
United States.
58.

After these illicit conversations, the administrator shared his “own wallet” BTC

address starting with 1Q4xw (Defendant Property 77), which could be used for “jihad.”
59.

The administrator complained about U.S. drones and subsequently stated that

“Bullets and bombs is all affordable, but the drone stuff, its very hard to unless u have like anti
aircraft stuff which is like millions of dollars. Here they shoot it with a ground to air missile.. its
possible to hit them but hard. Or a 23mm machine gun. U know those big guns attached to a car..”

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60.

RFS Cluster and Defendant Property 77 are further linked because they both, in

separate transitions, sent approximately 0.003769 BTC and 0.00235163 BTC respectively, at the
same time on or about July 23, 2020 to a cluster of BTC addresses with the main address starting
with 3QkrD.
61.

A majority of the BTC received by cluster 3QkrD is sent to a BTC address starting

with 1Kszb (Defendant Property 78), which is hosted at the same virtual currency exchange as
(Defendant Property 1).
62.

RFS Cluster also sent BTC to a cluster of BTC addresses with the main address

starting with 3KKa3. Like cluster 3QkrD, cluster 3KKa3 sent BTC to Defendant Property 78
multiple times.
Al Sadaqah
63.

Al Sadaqah (“charity” in Arabic) is a Syrian organization that operates social media

accounts on multiple platforms which seek to finance terrorism via BTC solicitations. They
described themselves as “an independent charity organization that is benefiting and providing the
Mujahidin in Syria with weapons, finical [sic] aid and other projects relating to the jihad. You can
donate safely and securely with Bitcoin.”
64.

On its Telegram channel, Al Sadaqah openly solicited donations via BTC to an

address starting with 15K9Z (Defendant Property 79, which clustered with Defendant Property
80).
65.

In one such post (depicted below), they directed people to “Donate anonymously

with Cryptocurrency” to Defendant Property 79, to support “the mujahidin in Syria with
weapons, financial aid, and other projects assisting the jihad.”

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66.

Example posts are shown here:

COUNT ONE – FORFEITURE
(18 U.S.C. § 981(A)(1)(G)(i))
67.

The United States incorporates by reference the allegations set forth in Paragraphs

1 to 66 above as if fully set forth herein.
68.

Al-Qaeda, HTS, and ANF are designated foreign terrorist organizations.

69.

The above described scheme involves these designated foreign terrorist

organizations’ campaigns to finance terrorism via BTC solicitations involving the Defendant
Properties.
70.

The Defendant Properties are subject to forfeiture to the United States, pursuant to

18 U.S.C. § 981(a)(1)(G)(i), as assets of a foreign terrorist organization engaged in planning or
perpetrating any federal crime of terrorism (as defined in section 2332b(g)(5)) against the United
States, citizens or residents of the United States, or their property, and as assets affording any
person a source of influence over any such entity or organization.

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PRAYER FOR RELIEF
WHEREFORE, the United States prays that notice issue on the Defendant Properties as
described above; that due notice be given to all parties to appear and show cause why the forfeiture
should not be decreed; that judgment be entered declaring that the Defendant Properties be
forfeited to the United States for disposition according to law; and that the United States be granted
such other relief as this Court may deem just and proper, together with the costs and disbursements
of this action.

Dated: August 13, 2020
Washington, D.C.

Respectfully submitted,
MICHAEL R. SHERWIN,
N.Y. Bar Number 4444188
ACTING UNITED STATES ATTORNEY

By:
/s/ Zia Faruqui
ZIA M. FARUQUI, D.C. Bar No. 494990
JESSICA BROOKS
Assistant United States Attorneys
Fourth Street, NW
Washington, DC 20530
(202) 252-7566 (main line)
and
ALEX HUGHES
DANIELLE ROSBOROUGH, D.C. Bar No. 1016234
Trial Attorney
National Security Division
United States Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20004
Office: (202) 514-0849 (main line)
Attorneys for the United States of America

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VERIFICATION
I, Christopher Janczewski, a Special Agent with the Internal Revenue Service-Criminal
Investigations, declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing
Verified Complaint for Forfeiture In Rem is based upon reports and information known to me
and/or furnished to me by other law enforcement representatives and that everything represented
herein is true and correct.
Executed on this 13th day of August, 2020.
/s/ Chris Janczewski
Special Agent Chris Janczewski
IRS-CI

_

I, Joseph Consavage, a Special Agent with the Homeland Security Investigation, declare
under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing Verified Complaint for
Forfeiture In Rem is based upon reports and information known to me and/or furnished to me by
other law enforcement representatives and that everything represented herein is true and correct.
Executed on this 13th day of August, 2020.

/s/ Joseph Consavage
Special Agent Joseph Consavage,
Homeland Security Investigation

_

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ATTACHMENT A:
Defendant Property

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37

BTC Address

1421chCK32pV32Tw5MQbiUiKWKvnmj7d91
3KhAHDfTuVnHUfRgQfVP4LcV8SHXpN51u7
3LZg4hHfbpLrJBagQqXp2agGbwrz9XpXai
163oWqgPk8fKhUqmHpNnoQhikfFjHyD3Pr
1JtyZYT4CKeKNyxMzbCpC9VJT6KTmeAKFN
3Bp2Eb87ApoMAsKPSQB2SAqLmRymjeLmtv
3HUhCkt44P3izoLZkK3rcx8NsZXKJdksh5
3Q4Nb6jUWAJQLq5NS7S92YPPCTcTyuSPhK
3Bo3cPpPjFzt6YHFfRoX6ufY1b2zzVf8mT
3HSK6MbuoewuttVBuYepEA4fyyPxHzZ6pB
1Awi7RLBGdT9qCo5SCB5y6Xea7MTb1F5Xc
33uWGWsWSTBw1KLM4UFPvxYvDJ5Xfo9s63
3G68RkhEDjwhajkDN83Z1611ZGnUZmvrUD
3QabnGEAWXrc7rvo1JcJBzUMhcifT7m6gd
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- 22 -

 Case 1:20-cv-02228 Document 1-1 Filed 08/13/20 Page 1 of 2
CIVIL COVER SHEET
JS-44 (Rev. 6/17 DC)

I. (a) PLAINTIFFS

DEFENDANTS

United States of America
c/o U.S. Attorney's Office
555 Fourth Street, N.W.
Washington, D.C. 20530

155 VIRTUAL CURRENCY ASSETS

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(IN U.S. PLAINTIFF CASES ONLY)

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________
(EXCEPT IN U.S. PLAINTIFF CASES)
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED

ATTORNEYS (IF KNOWN)

Zia M. Faruqui (202) 252-7117
Assistant United States Attorney
555 4th Street, N.W.,
Washington, DC 20530
II. BASIS OF JURISDICTION

III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR

(PLACE AN x IN ONE BOX ONLY)

o
o

1 U.S. Government
Plaintiff

o

2 U.S. Government
Defendant

o

3 Federal Question
(U.S. Government Not a Party)
4 Diversity
(Indicate Citizenship of
Parties in item III)

PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!
PTF
DFT

Citizen of this State
Citizen of Another State
Citizen or Subject of a
Foreign Country

o1 o1
o2 o2
o3 o3

Incorporated or Principal Place
of Business in This State
Incorporated and Principal Place
of Business in Another State
Foreign Nation

PTF

DFT

o4 o4
o5 o5
o6 o6

IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)

o

A. Antitrust
410 Antitrust

o

o

o

B. Personal Injury/
Malpractice
310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers Liability
340 Marine
345 Marine Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury
362 Medical Malpractice
365 Product Liability
367 Health Care/Pharmaceutical
Personal Injury Product Liability
368 Asbestos Product Liability

E. General Civil (Other)

Real Property
210 Land Condemnation
220 Foreclosure
230 Rent, Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
Personal Property
370 Other Fraud
371 Truth in Lending
380 Other Personal Property
Damage
385 Property Damage
Product Liability

C. Administrative Agency
Review
151 Medicare Act

Social Security
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
Other Statutes
891 Agricultural Acts
893 Environmental Matters
890 Other Statutory Actions (If
Administrative Agency is
Involved)

OR
Bankruptcy
422 Appeal 27 USC 158
423 Withdrawal 28 USC 157
Prisoner Petitions
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Conditions
560 Civil Detainee – Conditions
of Confinement
Property Rights
820 Copyrights
830 Patent
835 Patent – Abbreviated New
Drug Application
840 Trademark

o

o

D. Temporary Restraining
Order/Preliminary
Injunction

Any nature of suit from any category
may be selected for this category of
case assignment.
*(If Antitrust, then A governs)*

F. Pro Se General Civil
Federal Tax Suits
870 Taxes (US plaintiff or
defendant)
871 IRS-Third Party 26 USC
7609
Forfeiture/Penalty
625 Drug Related Seizure of
Property 21 USC 881
690 Other
Other Statutes
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
430 Banks & Banking
450 Commerce/ICC
Rates/etc.
460 Deportation

462 Naturalization
Application
465 Other Immigration
Actions
470 Racketeer Influenced
& Corrupt Organization
480 Consumer Credit
490 Cable/Satellite TV
850 Securities/Commodities/
Exchange
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of State
Statutes
890 Other Statutory Actions
(if not administrative agency
review or Privacy Act)

 Case 1:20-cv-02228 Document 1-1 Filed 08/13/20 Page 2 of 2

o

G. Habeas Corpus/
2255

o

K. Labor/ERISA
(non-employment)
710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
740 Labor Railway Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act

*(If pro se, select this deck)*

*(If pro se, select this deck)*

o

o

L. Other Civil Rights
(non-employment)

o

I. FOIA/Privacy Act
895 Freedom of Information Act
890 Other Statutory Actions
(if Privacy Act)

442 Civil Rights – Employment
(criteria: race, gender/sex,
national origin,
discrimination, disability, age,
religion, retaliation)

530 Habeas Corpus – General
510 Motion/Vacate Sentence
463 Habeas Corpus – Alien
Detainee

o

o

H. Employment
Discrimination

110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of
Judgment
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholder’s Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise

441 Voting (if not Voting Rights
Act)
443 Housing/Accommodations
440 Other Civil Rights
445 Americans w/Disabilities –
Employment
446 Americans w/Disabilities –
Other
448 Education

152 Recovery of Defaulted
Student Loan
(excluding veterans)

o

M. Contract

J. Student Loan

N. Three-Judge
Court
441 Civil Rights – Voting
(if Voting Rights Act)

V. ORIGIN

o 1 Original o 2 Removed o 3 Remanded
Proceeding

from State
Court

from Appellate
Court

o 4 Reinstated o 5 Transferred o 6 Multi-district o 7 Appeal to
or Reopened

from another
district (specify)

Litigation

District Judge
from Mag.
Judge

o 8 Multi-district
Litigation –
Direct File

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)

18 U.S.C. § 981(A)(1)(G)(i)
VII. REQUESTED IN
COMPLAINT

CHECK IF THIS IS A CLASS
ACTION UNDER F.R.C.P. 23

DEMAND $
JURY DEMAND:

VIII. RELATED CASE(S)
IF ANY

(See instruction)

YES

8/12/2020
DATE: _________________________

✘

NO

Check YES only if demanded in complaint

YES

NO

✘

If yes, please complete related case form

/s/ Zia M. Faruqui
SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44
Authority for Civil Cover Sheet

The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and services of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the
Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.
I.

COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.

III.

CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.

IV.

CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best
represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding
nature of suit found under the category of the case.

VI.

CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause.

VIII.

RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from
the Clerk’s Office.

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.