3 Matching Annotations
  1. Feb 2022
    1. V. Conclusion60. Based on the foregoing, your affiant submits that there is probable cause to believe that ILYA “DUTCH” LICHTENSTEIN and HEATHER MORGAN violated 18 U.S.C. § 1956(h), which makes it a crime in relevant part to conspire to conduct or attempt to conduct a financial transaction involving the proceeds of specified unlawful activity, knowing that the property involved in the financial transaction represents the proceeds of some form of unlawful activity, and knowing that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of specified unlawful activity. For purposes of this section, specified unlawful activity includes wire fraud, in violation of 18 U.S.C. § 1343, and computer fraud and abuse, in violation of 18 U.S.C. § 1030. 61. Your affiant submits there is also probable cause to believe that ILYA “DUTCH” LICHTENSTEIN and HEATHER MORGAN violated 18 U.S.C. § 371, which makes it a crime in relevant part for two or more persons to conspire to defraud the United States, or any agency thereof, in any manner or for any purpose, and to do any act to effect the object of the conspiracy.

      They're arresting them because they moved and sought to hide the movements of funds gained from an unlawful activity, not because they actually engaged in the original unlawful activity.

  2. Apr 2019
  3. Feb 2014