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  • U.S. v. Storm and Semenov Indictment

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    Adam Janofsky
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    U.S. v. Storm and Semenov Indictment

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    U.S. v. Storm and Semenov Indictment

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    © All Rights Reserved
    Descargue como PDF o lea en línea desde Scribd
    Marcar por contenido inapropiado
    3K vistas37 páginas

    U.S. v. Storm and Semenov Indictment

    Cargado por

    Adam Janofsky
    U.S. v. Storm and Semenov Indictment

    Copyright:

    © All Rights Reserved
    Descargue como PDF o lea en línea desde Scribd
    Marcar por contenido inapropiado
    de 37
    UNITED STATES DISTRICT COURT ‘SOUTHERN DISTRICT OF NEW YORK. UNITED STATES OF AMERICA, SBALED INDICTMENT 23Cr. ROMAN STORM and ScRIM 4 3 0 ca ee 2 4 Defendants OVERVIEW 1, From at east in or about 2019, upto and including a est on or shout August 8, 2022, ROMAN STORM and ROMAN SEMENOY, the defendans, developed, matketed, and operated a erypfocutency mixing service known as Tomado Cash, a business from which they sought to make, and dd make, substantial profits, The Tornado Cash service combined multiple unique features to execute anonymous financial transactions in various eryptourrencies for its ‘customers, Claiming to offer the Tomado Cath service asa “privacy” service, the defendants in fact knew that twas a haven fr criminals to engage in large-scale money laundering and saneions ‘evasion, Indeed as the defendants well knew, a substantial portion ofthe funds the Tomado Cash service processed were criminal proceed passed trough the Tornado Cash service for purposes ofconcealment, The defendants ls knew ta! the Tornado Cash service ecived funds fom, and provided services to, the Lazarus Group, a U.S -sautioned North Korean eybereime organization, by receiving, rnsfering, and doting in eryptocuteney fom an Ethereum wallet that was publicly ateibuted tothe Lazarus Group and designated as blocked propery 2. Atal times relevant to tis Inicement, ROMAN STORM, the defendant, was a naturalized United States citizen who reside in the United States, In aa interview video recorded ‘om or about October 4, 2021, STORM described himself asthe “cofounder of [the] Tomado Cash protocol.” Along with ROMAN SEMENOV, the defendant, and another person (*CC-1"), ‘STORM was one of three principal cofounders who developed and operated the Tomado Cash service from its intial public launch in 2019 up to and including atleast on or about August 8, 2022, when the United States Department of the Treasury's Office of Foreign Assets Control (COFAC”) announced the imposition of sanctions on Tomado Cash. 3. ROMAN SEMENOV, the defendant, isa Russian citizen, In a public posting to a social media service on or about March 20, 2022, SEMENOV shared a link to an article containing tn interview with himself, in which he was described as “one of the Founders of Tomado Cash.” ‘Along with ROMAN STORM, the defendant, and CC-1, SEMENOV was one of three principal cofounders who developed and operated the Tomado Cash service from its initial public launch in 2019 upto and including a easton or about August 8, 2022, ‘The Rthereum Blockshain 4. Biher (*ETH?) isa decentralized form of electronic cureney, o eryptocurreney, existing entirely on the Internet and not in any physical form. The cureney isnot issued by any government, bank, or company, but rather is generated and controlled automatically through ‘computer software operating on a “peer to peer” network. ETH transactions are processed colletvely by the computers composing the network, which are refered to a “nods. 5, To acquire ETH inthe frst instance, a user typically purchases t fom an ETH “exchanger.” In return fora commission, ETH exchangers accept payments of eurreny in some conventional form (cash, wire transfer, or otherwise), oF payments of another type of ceypiocunrency, and exchange the money for a comesponding number of ETH, based on ‘Muctuting exchange rate. Exchangers also accept payments of ETH and exchange the ETH back for conventional curreney or another type oferyptocurrency, again charging a commission forthe 6. Once auser acquires ETH, the ETHis stored as balance in an Ethereum “address,” designated by a sting of letters and numbers. The user can manage the Ethereum address with software or hardware known as an Ethereum “wallet.” which is controlled by a “private key” knovm tothe wallets owner. The Ethereum address is analogous to the account number fora bank avcount, while the wallet is analogous to a portfolio of bank accounts, since a single wallet can ‘contain multiple Fthereum addresses. A private key is akin toa PIN or password tha allows a user the ability to access and transfer value associated with the Ethereum address, Once an Ethereum, user fands an address in his or her wallet with ETH, the user can then use the ETH to conduct financial transactions, by transferring BTH to the Ethereum address of another user. This is ‘accomplished over the Internet, by sending a message announcing the transfer to the Etsercum peer-to-peer network 7. AIL ETH transactions are recorded on a public ledger known as the “Ethereum ‘lockchain,” which is stored on the nodes that make up the Ethereum peer-to-peer network, The ‘Ethereum blockchain reeords the balance held in each Fuhereum address and records all ETH ‘transactions between Ethereum addresses. This public ledger serves to prevent any user from. spending more ETH than the user holds in his or her Fthereum address. The public nature of the Ethereum blockchain also means thatthe movement of funds over the Ethereum blockechain ean be traced. However, the Ethereum blockchain only reflects the movement of funds between ‘anonymous Fthereum addresses and therefore cannot by itself be used to determine the identities ofthe persons involved inthe transactions, 8. The Fiheream blockchain also stores computer programs known as “smart contracts.” A smart contract is a computer applicetion hosted on the Ethereum blockchain that can hold ETH in an Ethereum address and release it when the smart contract receives instructions that comply with the smart contrat’s code. The Ethereum blockchain stores all transactions and balances associated with smart contracts. Background on the Tos lo Cash Service 9. ROMAN STORM and ROMAN SEMENOY, the defendants, working primarily with CC-1 (collectively, the “Tomado Cash founders), began developing the Tomado Cash service in or around 2019, They launched the service in or about August 2019, when they released «1 public statement on the Intemet with lnk tothe Tommado Cash website, where the Tomado Cash user interee and ther materials relating tothe Tornado Cash service were accessible, The announcement refered tothe Tornado Cash service asa “miner” and advertised that i “allows ‘you to send Ethereum eryptocurrency 100% anonymously using groundbreaking, non-custodial techmology based on slrong erypography? 10, In varius public and private statements ftom 2019 through a east on or about ‘August 8, 2022, the Tomado Cash founders described and marketed the Tomado Cash service as allowing its customers to conduct anonymous and virally untraceable financial transactions on the Ethercum blockchain, The Tomado Cash service provided a seamless and fully integrated service that exeeuted anonymous transactions in ETH and certain other eryptocurencies for its customers (the “Tomado Cash service"). Customers of the Torado Cash service could make

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