Case 3:16-cr-00227-SI Document 60 Filed 05/19/23 Page 1 of 3

JODI LINKER
1 Federal Public Defender
DAVID W. RIZK
2
Assistant Federal Public Defender
3 450 Golden Gate Avenue
San Francisco, CA 94102
4 Telephone: 415.436.7700
Facsimile: 415.436.7706
5 [email protected]

6
Counsel for Defendant VINNIK
7

8 IN THE UNITED STATES DISTRICT COURT

9 FOR THE NORTHERN DISTRICT OF CALIFORNIA
10
SAN FRANCISCO DIVISION
11

12 UNITED STATES OF AMERICA, Case No. CR 16-227 SI

13 Plaintiff,
14 DECLARATION OF DAVID RIZK
v. IN SUPPORT OF DEFENDANT’S
15 MOTION TO AMEND
ALEXANDER VINNIK, PROTECTIVE ORDER
16
Defendant.
17

18

19 I, David W. Rizk, state as follows:

20 I am the Assistant Federal Public Defender appointed to represent defendant Alexander Vinnik.

21 1. Attached hereto as Exhibit A is a copy of the proposed amended protective order in Mr.

22 Vinnik’s case.

23 2. Attached hereto as Exhibit B is the Department of Justice’s first press release concerning

24 Mr. Vinnik’s case.

25 3. Attached hereto as Exhibit C is a copy of the superseding indictment in Mr. Vinnik’s

26 case, redacted by the United States government.

27 4. Attached hereto as Exhibit D is a copy of the Department of Justice’s second press

28 release concerning Mr. Vinnik’s case.

US v. Vinnik, Case No. 16-227 SI
Rizk Decl. 1
 Case 3:16-cr-00227-SI Document 60 Filed 05/19/23 Page 2 of 3

1 5. Attached hereto as Exhibit E is a true and correct copy of the proposed protective order in

2 the case with defense counsel’s comments.

3 6. Attached hereto as Exhibit F is a true and correct copy of an email exchange between

4 government and defense counsel on September 20, 2022.

5 7. Attached hereto as Exhibit G is a true and correct copy of government counsel’s response

6 to defense counsel’s September 20, 2022 email.

7 8. Numerous individuals with knowledge of prisoner swap negotiations have emphasized to

8 the defense counsel the importance of publicly advocating for Mr. Vinnik’s inclusion in a

9 prisoner swap. By contrast, the Department of Justice has objected without citing any

10 legal basis to public advocacy for a prisoner exchange by Mr. Vinnik’s attorneys.

11 9. When the government refused to remove the restrictions on use of non-sensitive

12 discovery for any other purpose or disclosure to any third parties, defense counsel

13 repeatedly pressed government counsel at least three to four times in writing and in phone

14 calls to justify the restrictions in late 2022 and early 2023. In these discussions, the line

15 prosecutors conceded they were “not authorized” to make the changes requested by Mr.

16 Vinnik.

17 10. Based on defense counsel’s analysis of discovery produced by the government,

18 approximately one-fiftieth (1/50) of it by volume has been designated “Sensitive

19 Information” by the government

20 11. Attached hereto as Exhibit H is a true and correct copy of discovery marked as protected,

21 July 9, 2018 H.S.I. Report of Investigation.

22

23 I DECLARE under penalty of perjury that the foregoing is true and correct to the best of my

24 knowledge. Signed this 19th day of May, 2023, in San Francisco, California.

25

26 ___/S__________________________
DAVID WADE RIZK
27

28
US v. Vinnik, Case No. 16-227 SI
Rizk Decl. 2
 Case 3:16-cr-00227-SI Document 60 Filed 05/19/23 Page 3 of 3

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US v. Vinnik, Case No. 16-227 SI
Rizk Decl. 3
 Case 3:16-cr-00227-SI Document 60-1 Filed 05/19/23 Page 1 of 8

 
 Case 3:16-cr-00227-SI Document 60-1 Filed 05/19/23 Page 2 of 8

1 STEPHANIE M. HINDS (CABN 154284)

United States Attorney
2
THOMAS A. COLTHURST (CABN 99493)
3 Chief, Criminal Division

4 CLAUDIA QUIROZ (CABN 254419)

Assistant United States Attorney
5 C. ALDEN PELKER (MD)
Trial Attorney
6 Computer Crime & Intellectual Property Section
United States Department of Justice
7
450 Golden Gate Avenue, Box 36055
8 San Francisco, California 94102-3495
Telephone: (415) 436-7428
9 FAX: (415) 436-7234
[email protected]
10 [email protected]

11 Attorneys for United States of America

12
UNITED STATES DISTRICT COURT
13
NORTHERN DISTRICT OF CALIFORNIA
14
SAN FRANCISCO DIVISION
15

16 UNITED STATES OF AMERICA, ) Case No. CR 16-00227 SI

)
17 Plaintiff, ) STIPULATION AND PROTECTIVE ORDER
) [PROPOSED]
18 v. )
)
19 BTC-E, A/K/A CANTON BUSINESS )
CORPORATION, )
20 )
and )
21 )
ALEXANDER VINNIK, )
22 )
)
23 Defendants. )
)
24

25

26

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
1
 Case 3:16-cr-00227-SI Document 60-1 Filed 05/19/23 Page 3 of 8

1 With the agreement of the parties, the Court enters the following Protective Order:

2 1. Defendant is charged with in a 21-count indictment with the following offenses:

3 Operation of an Unlicensed Money Services Business, in violation of 18 U.S.C. § 1960 (Count One);

4 Conspiracy to Commit Money Laundering, in violation of 18 U.S.C. § 1956(h) (Count Two); Money

5 Laundering, in violation of 18 U.S.C. §§ 1956(a)(1)(A)(i) and (a)(1)(B)(i) (Counts Three through

6 Nineteen); and Engaging in Unlawful Monetary Transactions, in violation of 18 U.S.C. § 1957 (Counts

7 Twenty through Twenty-One). Upon receipt of a discovery request, the United States will produce

8 documents and other materials pertaining to the defendants and the charged offenses to defense counsel.

9 2. All materials provided by the United States in preparation for, or in connection with, any

10 stage of this case (collectively, “the materials”) may be used by the defendant and defense counsel

11 solely in connection with the defense of this case, and for no other purpose, and in connection with no

12 other proceeding, without further order of this Court. Neither the defendant nor any member of the

13 Defense Team shall provide any discovery material produced by the government—whether or not the

14 material constitutes or contains Sensitive Information within the meaning of this Order—to any third

15 party (i.e., any person who is not a member of the defense team) or make any public disclosure of the

16 same, other than in a court filing, without the government’s express written permission or further order

17 of this Court.

18 3. The United States will identify certain discovery materials as Sensitive Information by

19 marking such materials “CONFIDENTIAL– SUBJECT TO PROTECTIVE ORDER” or by providing

20 written notice identifying discovery materials as Sensitive Information. Sensitive Information is defined

21 as:

22 a. Personal Identifying Information of any individual (other than his or her name),

23 including any person’s date of birth, social security number, residence address,

24 telephone numbers, email addresses, driver’s license number, names of persons who

25 are minors, or criminal histories (“Personal Identifying Information”);

26 b. Financial Identifying Information of any individual or business, including bank

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
2
 Case 3:16-cr-00227-SI Document 60-1 Filed 05/19/23 Page 4 of 8

1 account numbers, credit or debit card numbers, account passwords, and taxpayer

2 identification numbers (“Financial Identifying Information”);

3 c. Medical records or other patient information of any individual covered by the Health

4 Insurance Portability and Accountability Act of 1996 (HIPAA) (“Medical

5 Information”);

6 d. Information that could reveal sensitive sources, techniques, information, or methods,

7 including information pertaining to technical or confidential human sources; and

8 e. Information regarding the existence and/or identities of other targets of the

9 investigation.

10 4. The government shall exercise reasonable care in determining which discovery materials

11 should be designated as Sensitive Information in order to avoid the over-designation of discovery

12 materials as Sensitive Information.

13 5. Defense counsel and their investigators, assistants, employees, and independent

14 contractors (collectively, “the Defense Team”) may review with the defendant all discovery material

15 produced by the government, but shall not provide a defendant with copies of, or permit defendant to

16 make copies of, or have unsupervised access to any discovery material produced by the government that

17 contains Sensitive Information, unless the Sensitive Information has first been entirely redacted from

18 the discovery materials. The government and defense counsel are ordered to work together to ensure

19 that these materials are protected, but that defendant has as much access to the materials as can be

20 provided consistent with this Court’s order. Discovery material that clearly pertains to a specific

21 defendant and does not contain Sensitive Information regarding any other person (e.g., defendant’s own

22 bank records, telephone records, and business records) may be provided to that defendant unredacted.

23 6. The Defense Team may show witnesses Sensitive Information in the course of preparing

24 a defense for trial or any related proceedings in this case, but only if (i) the witness, by reason of their

25 participation in the underlying events or conduct, would have seen or had reason to know such

26 information, or (ii) it is otherwise relevant to the defense of the case that the Defense Team discuss with

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
3
 Case 3:16-cr-00227-SI Document 60-1 Filed 05/19/23 Page 5 of 8

1 or show the witness Sensitive Information. Witnesses may only view Sensitive Information in the

2 presence of the Defense Team. No witness or potential witness may retain copies of discovery material

3 that contains Sensitive Information after his or her review of those materials with the Defense Team is

4 complete.

5 7. Defense counsel may also provide unredacted copies of Sensitive Information to any

6 experts retained to assist with the preparation of the defense in the captioned case. The defendant, all

7 members of the Defense Team, and any experts who receive Sensitive Information under this Order

8 shall be provided a copy of this Order along with those materials and shall initial and date the order

9 reflecting their agreement to be bound by it.

10 8. The Defense Team shall maintain Sensitive Information safely and securely and shall

11 exercise reasonable care in ensuring the confidentiality of those materials by not divulging the contents

12 or permitting anyone to see Sensitive Information except as set forth in this Protective Order.

13 9. This Order shall also apply to any copies made of any Sensitive covered by this Order.

14 10. If a party files a pleading that contains or attaches Sensitive Information subject to this

15 Order, the Sensitive Information must be filed under seal (accompanied by a request to file under seal)

16 and redacted from the public filing, unless otherwise ordered by the Court. The Clerk shall accept for

17 filing under seal any filings so marked by the parties pursuant to this Order.

18 11. After any judgment or disposition has become final and there are no pending

19 proceedings, challenges, appeals, or habeas motions in the case, counsel for defendant shall either

20 destroy discovery materials containing Sensitive Information (including any copies) within 30 days if

21 the defendant consents to such destruction, or retain the Sensitive Information and ensure that the

22 Sensitive Information will continue being kept under the conditions specified in this Order. After the

23 statutory period for filing a motion under 28 U.S.C. § 2255 has expired, the United States is free to

24 destroy documents and materials subject to this Order. If defendant is represented by counsel and files a

25 motion pursuant to 28 U.S.C. § 2255, the United States will provide counsel with the documents and

26 materials subject to this Protective Order under the terms of this Order.

27 Scope of this Order

STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
4
 Case 3:16-cr-00227-SI Document 60-1 Filed 05/19/23 Page 6 of 8

1 12. Modification Permitted. This stipulation is without prejudice to either party applying to

2 the Court to modify the terms of any protective order. This Court shall retain jurisdiction to modify this

3 Order upon motion of either party even after the conclusion of district court proceedings in this case.

4 13. No Waiver. The failure by the United States to designate any materials as “ Sensitive

5 Information” upon disclosure shall not constitute a waiver of the United States’ ability to later designate

6 the materials as Sensitive Information.

7 14. Disputes. The parties shall meet and confer prior to presenting any disputes arising

8 under this Order, such as whether materials should be designated Sensitive Information, to the Court for

9 adjudication.
10 15. No Ruling on Discoverability or Admissibility. This Order does not constitute a ruling

11 on the question of whether any particular material is properly discoverable or admissible and does not

12 constitute any ruling on any potential objection to the discoverability of any material.

13

14

15 IT IS SO STIPULATED. STEPHANIE M. HINDS

United States Attorney
16

17
Dated: __/s/___________________________________
18 CLAUDIA QUIROZ
19 Assistant United States Attorney
C. ALDEN PELKER
20 Trial Attorney, CCIPS Assistant United States
Attorney
21

22
__/s/___________________________________
23 DAVID RIZK
24 Counsel for Defendant ALEXANDER VINNIK

25

26 IT IS SO ORDERED.
27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
5
 Case 3:16-cr-00227-SI Document 60-1 Filed 05/19/23 Page 7 of 8

2 Dated: SUSAN ILLSTON

United States District Judge
3

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STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
6
 Case 3:16-cr-00227-SI Document 60-1 Filed 05/19/23 Page 8 of 8

1 By initialing below, I acknowledge that I have been provided and have reviewed a copy of

2 this Order and hereby agree to be bound by its terms:

4 INITIALS DATE

9
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27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
7
 Case 3:16-cr-00227-SI Document 60-2 Filed 05/19/23 Page 1 of 9

 
5/19/23, 12:51 PM Case
Northern3:16-cr-00227-SI Document
District of California | Russian 60-2 Exchange
National And Bitcoin Filed 05/19/23 Page
Charged In 21-Count 2 of 9For Operating Alleged In…
Indictment

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PRESS RELEASE

Russian National And Bitcoin Exchange Charged In 21-Count

Indictment For Operating Alleged International Money
Laundering Scheme And Allegedly Laundering Funds From
Hack Of Mt. Gox

Wednesday, July 26, 2017

Share

For Immediate Release

U.S. Attorney's Office, Northern District of California

Defendant Alexander Vinnik Was Arrested in Greece to Face Charges in the

United States; Bitcoin Exchange Alleged to Have Received Deposits Valued
at Over $4 Billion

SAN FRANCISCO – A grand jury in the Northern District of California has indicted a Russian
national and an organization he allegedly operated, BTC-e, for operating an unlicensed money
service business, money laundering, and related crimes. The announcement was made by U.S.
TOP
Attorney Brian J. Stretch for the Northern District of California; Acting Assistant Attorney

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General Kenneth A. Blanco of the Justice Department’s Criminal Division; Internal Revenue
Service (IRS) Criminal Investigation Chief Don Fort; Immigration and Customs Enforcement’s
(ICE) Homeland Security Investigations (HSI) Acting Executive Associate Director Derek
Benner; Federal Bureau of Investigation (FBI) Special Agent in Charge of the Louisville Division
Amy Hess; United States Secret Service (USSS) Special Agent in Charge of the Criminal
Investigative Division Michael D’Ambrosio; Federal Deposit Insurance Corporation (FDIC), Office
of the Inspector General, Inspector General Jay N. Lerner; and Acting Director of the U.S.
Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), Jamal El-Hindi.

“Cryptocurrencies such as Bitcoin provide people around the world new and innovative ways of
engaging in legitimate commerce. As this case demonstrates, however, just as new computer
technologies continue to change the way we engage each other and experience the world, so
too will criminals subvert these new technologies to serve their own nefarious purposes,” said
U.S. Attorney Stretch.  “This office will continue to devote the necessary resources to ensure
that money launderers and cyber-criminals are detected, apprehended, and brought to justice
wherever and however they use the internet to commit their crimes.”

"As this case demonstrates, the Criminal Division employs a multi-faceted approach to
dismantling criminal enterprises, by prosecuting the criminal actors themselves, and by
shutting down their ability to monetize their crimes through entities that facilitate money
laundering," said Acting Assistant Attorney General Blanco.  "The Criminal Division will work
tirelessly to identify those who use technology to conduct and obscure their criminal activity, as
we ensure there are no safe havens from U.S. justice for those who seek to victimize
Americans."

“Homeland Security Investigations is strongly committed to tracking down criminals who seek
to strike at the foundations of global financial security through complex money laundering
schemes,” said HSI Acting Executive Associate Director Derek Benner. “The resulting
indictment is a clear representation of why our close law enforcement partnerships are vital to
our shared missions. HSI will continue to aggressively target those who deliberately seek to
exploit financial systems for personal gain."

“Mr. Vinnik is alleged to have committed and facilitated a wide range of crimes that go far
beyond the lack of regulation of the bitcoin exchange he operated.  Through his actions, it is
alleged that he stole identities, facilitated drug trafficking, and helped to launder criminal
proceeds from syndicates around the world,” said Chief Don Fort, IRS Criminal Investigation.
 “Exchanges like this are not only illegal, but they are a breeding ground for stolen identity
refund fraud schemes and other types of tax fraud.  When there is no regulation and criminals
are left unchecked, this scenario is all too common. The takedown of this large virtual currency
exchange should send a strong message to cyber-criminals and other unregulated exchanges
across the globe.” TOP

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“BTC-e was noted for its role in numerous ransomware and other cyber-criminal activity; its
take-down is a significant accomplishment, and should serve as a reminder of our global reach
in combating transnational cyber crime,” said Special Agent in Charge of the USSS Criminal
Investigative Division Michael D’Ambrosio. “We are grateful for the efforts of our law
enforcement partners in achieving this significant result.”

"The arrest of Alexander Vinnik is the result of a multi-national effort and clearly displays the
benefits of global cooperation among US and international law enforcement,” said FBI Special
Agent in Charge Hess.  “This investigation demonstrates the long-term commitment given to
identifying and pursuing criminals world-wide with a whole of government approach. This was a
highly complex investigation that has only reached this stage due to the persistent and
dedicated efforts of all the parties involved.  We must continue to impose real costs on
criminals, no matter who they are or where they attempt to hide."

“The Federal Deposit Insurance Corporation Office of Inspector General works to ensure the
integrity of the financial service sector and is committed to holding accountable those involved
in criminal activity that undermine its integrity,” said Inspector General Lerner.  “This
investigation demonstrates what can be achieved among the cooperative partnerships in the
domestic and international law enforcement community.”

The indictment describes Alexander Vinnik, 37, a Russian citizen, as the owner and operator of
multiple BTC-e accounts, including administrator accounts, and also a primary beneficial owner
of BTC-e’s managing shell company, Canton Business Corporation. According to the indictment,
numerous withdrawals from BTC-e administrator accounts went directly to Vinnik’s personal
bank accounts. The indictment further alleges that proceeds from well-known hacks and thefts
from bitcoin exchanges were funded through a BTC-e administrator account associated with
Vinnik.  Vinnik was arrested in Greece on July 25.  

According to the indictment unsealed today, BTC-e, founded in 2011, was one of the world’s
largest and most widely used digital currency exchanges.  The indictment alleges that BTC-e
allowed its users to trade in the digital currency “Bitcoin” with high levels of anonymity.  The
indictment alleges that although Bitcoin has known legitimate uses, the virtual currency, like
cash, can be used to facilitate illicit transactions and to launder criminal proceeds.  According
to the indictment, since its inception, Vinnik and others developed a customer base for BTC-e
that was heavily reliant on criminals, including by not requiring users to validate their identity,
obscuring and anonymizing transactions and source of funds, and by lacking any anti-money
laundering processes. The indictment alleges BTC-e was operated to facilitate transactions for
cybercriminals worldwide and received the criminal proceeds of numerous computer intrusions
and hacking incidents, ransomware scams, identity theft schemes, corrupt public officials, and
narcotics distribution rings.  Thus, the indictment alleges, BTC-e was used to facilitate crimes
ranging from computer hacking, to fraud, identity theft, tax refund fraud schemes, public TOP

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corruption, and drug trafficking. The investigation has revealed that BTC-e received more than
$4 billion worth of bitcoin over the course of its operation.

As to Vinnik, the indictment alleges that he received funds from the infamous computer
intrusion or “hack” of Mt. Gox – an earlier digital currency exchange that eventually failed, in
part due to losses attributable to hacking.  The indictment alleges that Vinnik obtained funds
from the hack of Mt. Gox and laundered those funds through various online exchanges,
including his own BTC-e and a now defunct digital currency exchange, Tradehill, based in San
Francisco, California.  The indictment alleges that by moving funds through BTC-e, Vinnik
sought to conceal and disguise his connection with the proceeds from the hacking of Mt. Gox
and the resulting investigation.

As for defendant BTC-e, the indictment alleges that, despite doing substantial business in the
United States, BTC-e was not registered as a money services business with the U.S. Department
of the Treasury, had no anti-money laundering process, no system for appropriate “know your
customer” or “KYC” verification, and no anti-money laundering program as required by federal
law.  According to the company’s website, BTC-e is located in Bulgaria but organized or
otherwise subject to the laws of Cyprus.  The exchange allegedly maintains a base of operations
in the Seychelles Islands and its web domains are registered to shell companies in, among other
places, Singapore, the British Virgin Islands, France, and New Zealand. 

The indictment charges BTC-e and Vinnik with one count of operation of an unlicensed money
service business, in violation of 18 U.S.C. § 1960, and one count of conspiracy to commit money
laundering, in violation of 18 U.S.C. § 1956(h).  In addition, the indictment charges Vinnik with
seventeen counts of money laundering, in violation of 18 U.S.C. § 1956(a)(1), and two counts of
engaging in unlawful monetary transactions, in violation of 18 U.S.C. § 1957. An indictment
merely alleges that crimes have been committed, and the defendants are presumed innocent
until proven guilty beyond a reasonable doubt.  

FinCEN today assessed a $110 million civil money penalty against BTC-e  for willfully violating
U.S. anti-money laundering (AML) laws.  Alexander Vinnik was assessed $12 million for his role
in the violations.

“We will hold accountable foreign-located money transmitters, including virtual currency
exchangers, that do business in the United States when they willfully violate U.S. AML laws,”
said Acting FinCEN Director Jamal El-Hindi.  “Today’s action should be a strong deterrent to
anyone who thinks that they can facilitate ransomware, dark net drug sales, or conduct other
illicit activity using encrypted virtual currency.  Treasury’s FinCEN team and our law
enforcement partners will work with foreign counterparts across the globe to appropriately
oversee virtual currency exchangers and administrators who attempt to subvert U.S. law and
avoid complying with U.S. AML safeguards.”   TOP

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If convicted of these crimes, Vinnik faces the following maximum penalties:      

 

Violation Statute Maximum Penalty

operation of an unlicensed
18 U.S.C. § 1960 5 years of imprisonment
money service business

20 years of imprisonment
conspiracy to commit money and a $500,000 fine or twice
18 U.S.C. § 1956(h)
laundering the value of the property
involved in the transaction

20 years of imprisonment
and a $500,000 fine or twice
money laundering 18 U.S.C. § 1956(a)(1) the value of the property
involved in the transaction
(each count)

10 years of imprisonment and

a $500,000 fine or twice the
engaging in unlawful
18 U.S.C. § 1957 value of the property
monetary transactions
involved in the transaction
(each count)

Additional fines, restitution, and supervised release also may be ordered.  However, any
sentence will be imposed by the court only after consideration of the U.S. Sentencing
Guidelines and the federal statute governing the imposition of a sentence, 18 U.S.C. § 3553.

This case is being investigated by the Internal Revenue Service (the Oakland Calif., Field Office
and Cyber Crime Unit in Washington, D.C.); Department of Homeland Security, Homeland
Security Investigations; FBI; U.S. Secret Service Criminal Investigative Division; and Federal
Deposit Insurance Corporation, Office of the Inspector General.  The case is being prosecuted
by the U.S. Attorney’s Office for the Northern District of California and the Criminal Division’s
Computer Crime and Intellectual Property Section.  The Criminal Division’s Office of
International Affairs provided substantial assistance on the case.

Updated April 17, 2023

TOP

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Indictment

Attachment
Vinnik Superseding Indictment Redacted   [PDF, 5 MB]

Topic

CYBERCRIME

Component

USAO - California, Northern

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National And Bitcoin Filed 05/19/23 Page
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Northern District of California

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5/19/23, 12:56 PM Case 3:16-cr-00227-SI Document
Alleged Russian Cryptocurrency 60-4 Extradited
Money Launderer Filed 05/19/23 Page
to United States | OPA2 of 3
| Department of Justice

An official website of the United States government

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JUSTICE NEWS

Department of Justice

Office of Public Affairs

FOR IMMEDIATE RELEASE Friday, August 5, 2022

Alleged Russian Cryptocurrency Money Launderer Extradited to United States

Defendant Extradited from Greece to Face Charges Stemming from the Operation of BTC-e, an Illicit
Bitcoin Exchange Alleged to Have Received Deposits Valued at Over $4 Billion

The alleged operator of the illicit cryptocurrency exchange BTC-e was extradited yesterday from Greece to the United
States to face charges in the Northern District of California.

“After more than five years of litigation, Russian national Alexander Vinnik was extradited to the United States yesterday
to be held accountable for operating BTC-e, a criminal cryptocurrency exchange, which laundered more than $4 billion
of criminal proceeds,” said Assistant Attorney General Kenneth A. Polite, Jr. of the Justice Department’s Criminal
Division. “This extradition demonstrates the Department’s commitment to investigating and dismantling illicit cyber
activity and would not have been possible without the relentless work of the Justice Department’s Office of International
Affairs. The Justice Department thanks the Government of Greece, particularly the Ministry of Justice, for all their efforts
in securing the defendant’s transfer to the United States.”

Alexander Vinnik, 42, a Russian citizen, was charged in a 21-count superseding indictment in January 2017. Vinnik was
taken into custody in Greece in July 2017 at the request of the United States. He made his initial appearance earlier
today in federal court in San Francisco before U.S. Magistrate Judge Sallie Kim.

According to the indictment, Vinnik and his co-conspirators allegedly owned, operated, and administrated BTC-e, a
significant cybercrime and online money laundering entity that allowed its users to trade in bitcoin with high levels of
anonymity and developed a customer base heavily reliant on criminal activity. 

The indictment alleges BTC-e facilitated transactions for cybercriminals worldwide and received criminal proceeds from
numerous computer intrusions and hacking incidents, ransomware scams, identity theft schemes, corrupt public
officials, and narcotics distribution rings, and was used to facilitate crimes ranging from computer hacking, to fraud,
identity theft, tax refund fraud schemes, public corruption, and drug trafficking. The investigation has revealed that BTC-
e received more than $4 billion worth of bitcoin over the course of its operation.

Despite doing substantial business in the United States, the indictment alleges that BTC-e was not registered as a
money services business with the U.S. Department of Treasury, had no anti-money laundering process, no system for
appropriate “know your customer” or “KYC” verification, and no anti-money laundering program as required by federal
law. 

In 2017, FinCEN assessed a civil money penalty against BTC-e for willfully violating U.S. anti-money laundering (AML)
laws and against Vinnik for his role in the violations. A civil matter to enforce civil monetary penalties, in the amount of
$88,596,314 as to BTC-e and $12 million as to Vinnik, is pending in the Northern District of California.

https://www.justice.gov/opa/pr/alleged-russian-cryptocurrency-money-launderer-extradited-united-states 1/2
5/19/23, 12:56 PM Case 3:16-cr-00227-SI Document
Alleged Russian Cryptocurrency 60-4 Extradited
Money Launderer Filed 05/19/23 Page
to United States | OPA3 of 3
| Department of Justice

The indictment charges BTC-e and Vinnik with one count of operation of an unlicensed money service business, and
one count of conspiracy to commit money laundering. In addition, the indictment charges Vinnik with 17 counts of
money laundering and two counts of engaging in unlawful monetary transactions.

The FBI, IRS Criminal Investigation (Oakland Field Office and Cyber Crime Unit, Washington, D.C.), Homeland Security
Investigations, and U.S. Secret Service Criminal Investigative Division are investigating the case.

Trial Attorney C. Alden Pelker of the Justice Department’s Computer Crime and Intellectual Property Section, and
Assistant U.S. Attorney Claudia Quiroz of the U.S. Attorney’s Office for the Northern District of California are
prosecuting the case.

The Justice Department’s National Cryptocurrency Enforcement Team provided substantial assistance. The extradition
request was handled by the Justice Department’s Office of International Affairs.

The Justice Department thanks the Greek Ministry of Justice for its cooperation in securing the defendant’s transfer to
the United States.

An indictment is merely an allegation. All defendants are presumed innocent until proven guilty beyond a reasonable
doubt in a court of law.

Topic(s): 
Cybercrime

Component(s): 
Criminal Division
Federal Bureau of Investigation (FBI)

Press Release Number: 

22-844
Updated August 5, 2022

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Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 1 of 11
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 2 of 11

1 STEPHANIE M. HINDS (CABN 154284)

United States Attorney
2
THOMAS A. COLTHURST (CABN 99493)
3 Chief, Criminal Division

4 CLAUDIA QUIROZ (CABN 254419)

Assistant United States Attorney
5 C. ALDEN PELKER (MD)
Trial Attorney
6 Computer Crime & Intellectual Property Section
United States Department of Justice
7
450 Golden Gate Avenue, Box 36055
8 San Francisco, California 94102-3495
Telephone: (415) 436-7428
9 FAX: (415) 436-7234
[email protected]
10 [email protected]

11 Attorneys for United States of America

12
UNITED STATES DISTRICT COURT
13
NORTHERN DISTRICT OF CALIFORNIA
14
SAN FRANCISCO DIVISION
15

16 UNITED STATES OF AMERICA, ) Case No. CR 16-00227 SI

)
17 Plaintiff, ) STIPULATION AND PROTECTIVE ORDER
) [PROPOSED]
18 v. )
)
19 BTC-E, A/K/A CANTON BUSINESS )
CORPORATION, )
20 )
and )
21 )
ALEXANDER VINNIK, )
22 )
)
23 Defendants. )
)
24

25

26

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
1
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 3 of 11

1 With the agreement of the parties, the Court enters the following Protective Order:

2 1. Defendant is charged with in a 21-count indictment with the following offenses:

3 Operation of an Unlicensed Money Services Business, in violation of 18 U.S.C. § 1960 (Count One);

4 Conspiracy to Commit Money Laundering, in violation of 18 U.S.C. § 1956(h) (Count Two); Money

5 Laundering, in violation of 18 U.S.C. §§ 1956(a)(1)(A)(i) and (a)(1)(B)(i) (Counts Three through

6 Nineteen); and Engaging in Unlawful Monetary Transactions, in violation of 18 U.S.C. § 1957 (Counts

7 Twenty through Twenty-One). Upon receipt of a discovery request, the United States will produce

8 documents and other materials pertaining to the defendants and the charged offenses to defense counsel.

9 All Materials

10 2. The1United States will identify discovery materials as Protected Information by marking

11 such materials “CONFIDENTIAL– SUBJECT TO PROTECTIVE ORDER” or by providing written

12 notice identifying discovery materials as Protected Information. Protected Information is defined as:

13 a. Personal Identifying Information of any individual (other than his or her name),

14 including any person’s date of birth, social security number, residence address,

15 telephone numbers, email addresses, driver’s license number, names of persons who

16 are minors, or criminal histories (“Personal Identifying Information”);

17 b. Financial Identifying Information of any individual or business, including bank

18 account numbers, credit or debit card numbers, account passwords, and taxpayer

19 identification numbers (“Financial Identifying Information”); and

20 c. Medical records or other patient information of any individual covered by the Health

21 Insurance Portability and Accountability Act of 1996 (HIPAA) (“Medical

22 Information”).

23 3. The government shall exercise reasonable care in determining which discovery materials

24 should be designated as Protected Information in order to avoid the over-designation of discovery

25 materials as Protected Information.

26 4. The defendant and defense counsel shall not disclose the Protected Information or their

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
2
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 4 of 11

Summary of Comments on

Page: 3
Number: 1 Author: Rizk, David Date: 9/13/2022 2:39:00 PM
What is the justification for this restriction, which is not usually adopted in this district?
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 5 of 11

1 contents directly or indirectly to any person or entity other than persons employed to assist in the

2 defense (i.e., the “Defense Team,” as identified below), persons who are interviewed as potential

3 witnesses, counsel for potential witnesses, and other persons to whom the Court may authorize

4 disclosure (collectively, “authorized persons”).

1
5 5. Defense counsel and their investigators, assistants, employees, and independent

6 contractors (collectively, “the Defense Team”) may review with the defendant all discovery material

7 produced by the government, but shall not provide a defendant with copies of, or permit defendant to

8 make copies of, or have unsupervised access to any discovery material produced by the government that

9 contains Protected Information, unless the Protected Information has first been entirely redacted from

10 the discovery materials. The government and defense counsel are ordered to work together to ensure

11 that these materials are protected, but that defendant has as much access to the materials as can be

12 provided consistent with this Court’s order. Discovery material that clearly pertains to a specific

13 defendant and does not contain Protected Information regarding any other person (e.g., defendant’s own

14 bank records, telephone records, and business records) may be provided to that defendant unredacted.

15 6. The Defense Team may show witnesses Protected Information in the course of preparing

16 a defense for trial or any related proceedings in this case, but only if (i) the witness, by reason of their

17 participation in the underlying events or conduct, would have seen or had reason to know such

18 information, or (ii) it is otherwise relevant to the defense of the case that the Defense Team discuss with

19 or show the witness Protected Information. Witnesses may only view Protected Information in the

20 presence of the Defense Team. No witness or potential witness may retain copies of discovery material

21 that contains Protected Information after his or her review of those materials with the Defense Team is

22 complete.

23 7. Defense counsel may also provide unredacted copies of Protected Information to any

24 experts retained to assist with the preparation of the defense in the captioned case. The defendant, all

25 members of the Defense Team, and any experts who receive Protected Information under this Order

26 shall be provided a copy of this Order along with those materials and shall initial and date the order

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
3
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 6 of 11

Page: 4
Number: 1 Author: Rizk, David Date: 9/13/2022 3:49:00 PM
This is inconsistent with
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 7 of 11

1 reflecting their agreement to be bound by it.

2 8. The Defense Team shall maintain Protected Information safely and securely and shall

3 exercise reasonable care in ensuring the confidentiality of those materials by not divulging the contents

4 or permitting anyone to see Protected Information except as set forth in this Protective Order.

5 9. This Order shall also apply to any copies made of any materials covered by this Order.

6 10. If a party files a pleading that contains or attaches Protected Information subject to this
1
7 Order, the Protected Information must be filed under seal (accompanied by a request to file under seal)

8 and redacted from the public filing, unless otherwise ordered by the Court. The Clerk shall accept for

9 filing under seal any filings so marked by the parties pursuant to this Order.

10 11. After any judgment or disposition has become final and there are no pending
2
11 proceedings, challenges, appeals, or habeas motions in the case, counsel for defendant shall either

12 destroy discovery materials containing Protected Information (including any copies) within 30 days if

13 the defendant consents to such destruction, or retain the Protected Information and ensure that the

14 Protected Information will continue being kept under the conditions specified in this Order. After the

15 statutory period for filing a motion under 28 U.S.C. § 2255 has expired, the United States is free to

16 destroy documents and materials subject to this Order. If defendant is represented by counsel and files a

17 motion pursuant to 28 U.S.C. § 2255, the United States will provide counsel with the documents and

18 materials subject to this Protective Order under the terms of this Order.
3
19 Scope of this Order

20 12. Modification Permitted. This stipulation is without prejudice to either party applying to

21 the Court to modify the terms of any protective order. This Court shall retain jurisdiction to modify this

22 Order upon motion of either party even after the conclusion of district court proceedings in this case.

23 13. No Waiver. The failure by the United States to designate any materials as “Protected

24 Information” upon disclosure shall not constitute a waiver of the United States’ ability to later designate

25 the materials as Protected Information.

26 14. Disputes. The parties shall meet and confer prior to presenting any disputes arising

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
4
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 8 of 11

Page: 5
Number: 1 Author: Rizk, David Date: 9/13/2022 3:24:00 PM
This entire paragraph appears to be directed at the same purpose as the last paragraph (#9 below). I think #9 is sufficient and have concerns about the rest of
this paragraph, especially the portion highlighted below.

Number: 2 Author: Rizk, David Date: 9/13/2022 3:22:00 PM

The way this is phrased in particular is too ambiguous and unworkable. I’ve never seen such a restriction in a protective order and I cannot agree to it.

Number: 3 Author: Rizk, David Date: 9/20/2022 4:39:00 PM

It does not make sense to have another whole section on “sensitive materials” when they are already covered by the standard definition of Protected
Information.
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 9 of 11

1 under this Order, such as whether materials should be designated Protected Infromation, to the Court for

2 adjudication.

3 15. No Ruling on Discoverability or Admissibility. This Order does not constitute a ruling

4 on the question of whether any particular material is properly discoverable or admissible and does not

5 constitute any ruling on any potential objection to the discoverability of any material.

8 IT IS SO STIPULATED. STEPHANIE M. HINDS

United States Attorney
9

10
Dated: __/s/___________________________________
11 CLAUDIA QUIROZ
12 Assistant United States Attorney
C. ALDEN PELKER
13 Trial Attorney, CCIPS Assistant United States
Attorney
14

15
__/s/___________________________________
16 DAVID RIZK
17 Counsel for Defendant ALEXANDER VINNIK

18

19 IT IS SO ORDERED.
20

21 Dated: SUSAN ILLSTON

United States District Judge
22

23
1
24

25

26

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
5
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 10 of 11

Page: 6
Number: 1 Author: Rizk, David Date: 9/13/2022 3:41:00 PM
This is unworkable – we have to be able to disclose Sensitive Information to witnesses as needed to defend the case, same as Protected Information.
 Case 3:16-cr-00227-SI Document 60-5 Filed 05/19/23 Page 11 of 11

1 By initialing below, I acknowledge that I have been provided and have reviewed a copy of

2 this Order and hereby agree to be bound by its terms:

4 INITIALS DATE

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27
STIPULATION AND PROTECTIVE ORDER [PROPOSED]
28 CR 16-00227 SI
6
Case 3:16-cr-00227-SI Document 60-6 Filed 05/19/23 Page 1 of 3
 Case 3:16-cr-00227-SI Document 60-6 Filed 05/19/23 Page 2 of 3

From: David Rizk

To: Quiroz, Claudia (USACAN)
Cc: Pelker, Catherine (CRM)
Subject: RE: Vinnik - Draft Protective Order
Date: Tuesday, September 20, 2022 4:47:00 PM
Attachments: 2022.09.12 Proposed Protective Order (Vinnik) (sent to DR - REDLINE).docx

Hi,
Sorry, I’ve just been busy. I would also like to get this resolved quickly. I am concerned that we are
going to have a dispute around paragraph 2, so I would like to know what the justification for it is.
I’m attaching a redline along the lines of the issues I discussed with Claudia the other day, and happy
to discuss them further.
David

From: Quiroz, Claudia (USACAN) <[email protected]>

Sent: Tuesday, September 20, 2022 11:42 AM
To: David Rizk <[email protected]>
Cc: Pelker, Catherine (CRM) <[email protected]>
Subject: RE: Vinnik - Draft Protective Order

Hi David,

Just wanted to follow up on my email below re the protective order. We would like to get
it sorted out this week if possible. Let us know if you want to get on a call to discuss.

Thanks!

Claudia

From: Quiroz, Claudia (USACAN)

Sent: Friday, September 16, 2022 1:39 PM
To: [email protected]
Cc: Pelker, Catherine (CRM) <[email protected]>
Subject: RE: Vinnik - Draft Protective Order

Hi David,

I am writing to follow up on our conversation regarding the draft protective order we sent
you. As I understand it, the protective order that is being negotiated between our offices is
designed for basic, mail-fraud-type cases and can be used a starting point for other, more
complex matters (which is what we have done here). This matter is unique enough to
justify additional protections. I consulted with Alden and two supervisors in my office
(including my direct supervisor) about the draft we sent you and we consider the way it is
structured it to be appropriate for this case. If you want to send us edits to specific
 Case 3:16-cr-00227-SI Document 60-6 Filed 05/19/23 Page 3 of 3

language we will consider them but we believe that paragraph 2 in particular should
remain as written. Please let us know how you wish to proceed.

Thanks,

Claudia

From: Quiroz, Claudia (USACAN)

Sent: Tuesday, September 13, 2022 9:45 AM
To: [email protected]
Cc: Pelker, Catherine (CRM) <[email protected]>
Subject: Vinnik - Draft Protective Order

Hi David,

Attached is a draft protective order for your review. This version has been approved by
my supervisors. Please let us know if you have any questions.

Thanks,

Claudia Quiroz
Assistant U.S. Attorney
Northern District of California
450 Golden Gate Avenue | San Francisco, CA 94102
Tel: (415) 436-7428 | Fax: (415) 436-7234
Cell: (415) 802-4637
Email: [email protected]
 Case 3:16-cr-00227-SI Document 60-7 Filed 05/19/23 Page 1 of 2

 
 Case 3:16-cr-00227-SI Document 60-7 Filed 05/19/23 Page 2 of 2

Mikaela M Hansen

From: Quiroz, Claudia (USACAN) <[email protected]>

Sent: Friday, September 16, 2022 1:39 PM
To: David Rizk
Cc: Pelker, Catherine (CRM)
Subject: RE: Vinnik - Draft Protective Order

Hi David, 
 
I am writing to follow up on our conversation regarding the draft protective order we sent you.  As I 
understand it, the protective order that is being negotiated between our offices is designed for basic, mail‐
fraud‐type cases and can be used a starting point for other, more complex matters (which is what we have 
done here).  This matter is unique enough to justify additional protections.  I consulted with Alden and two 
supervisors in my office (including my direct supervisor) about the draft we sent you and we consider the way 
it is structured it to be appropriate for this case.  If you want to send us edits to specific language we will 
consider them but we believe that paragraph 2 in particular should remain as written.  Please let us know how 
you wish to proceed.  
 
Thanks, 
 
Claudia 
 
 
From: Quiroz, Claudia (USACAN)  
Sent: Tuesday, September 13, 2022 9:45 AM 
To: [email protected] 
Cc: Pelker, Catherine (CRM) <[email protected]> 
Subject: Vinnik ‐ Draft Protective Order 
 
Hi David, 
 
Attached is a draft protective order for your review.  This version has been approved by my 
supervisors.  Please let us know if you have any questions. 
 
Thanks, 
 
Claudia Quiroz 
Assistant U.S. Attorney  
Northern District of California 
450 Golden Gate Avenue | San Francisco, CA 94102  
Tel: (415) 436‐7428 | Fax: (415) 436‐7234 
Cell: (415) 802‐4637 
Email: [email protected] 
 

1
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