Page:US District Court, Southern District of New York.-Liberty Reserve Indictment.pdf/1

 UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

The Grand Jury charges:

1. Incorporated in Costa Rica in 2006, LIBERTY RESERVE S.A. ("LIBERTY RESERVE"), the defendant, has for years operated one of the world's most widely used digital currencies. Through its website, www.libertyreserve.com, LIBERTY RESERVE has provided its users with what it described as "instant, real-time currency for international commerce," which can be used to "send