Page:Netyksho et al indictment.pdf/21

 {| personal email account personal email account DCCC computer network DCCC computer network DCCC computer network DNC computer network personal email account personal email account
 * Count|||Approximate Date|||Victim|||Means of Identification
 * 2||| March 21, 2016 |||Victim 3|||Username and password for
 * 2||| March 21, 2016 |||Victim 3|||Username and password for
 * 3|||March 25, 2016|||Victim 1|||Username and password for
 * 3|||March 25, 2016|||Victim 1|||Username and password for
 * 4|||April 12, 2016|||Victim 4|||Username and password for
 * 4|||April 12, 2016|||Victim 4|||Username and password for
 * 5|||April 15, 2016|||Victim 5|||Username and password for
 * 5|||April 15, 2016|||Victim 5|||Username and password for
 * 6|||April 18, 2016|||Victim 6|||Username and password for
 * 6|||April 18, 2016|||Victim 6|||Username and password for
 * 7|||May 10, 2016|||Victim 7|||Username and password for
 * 7|||May 10, 2016|||Victim 7|||Username and password for
 * 8|||June 2, 2016|||Victim 2|||Username and password for
 * 8|||June 2, 2016|||Victim 2|||Username and password for
 * 9|||July 6, 2016|||Victim 8|||Username and password for
 * 9|||July 6, 2016|||Victim 8|||Username and password for
 * }
 * }

All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2.

56. Paragraphs 1 through 19, 21 through 49, and 55 are re-alleged and incorporated by reference as if fully set forth herein.

57. To facilitate the purchase of infrastructure used in their hacking activity—including hacking into the computers of U.S. persons and entities involved in the 2016 U.S. presidential election and releasing the stolen documents—the Defendants conspired to launder the equivalent of more than $95,000 through a web of transactions structured to capitalize on the perceived anonymity of cryptocurrencies such as bitcoin.

58. Although the Conspirators caused transactions to be conducted in a variety of currencies, including U.S. dollars, they principally used bitcoin when purchasing servers, registering domains, and otherwise making payments in furtherance of hacking activity. Many of these payments were