Page:US District Court, Southern District of New York.-Liberty Reserve Indictment.pdf/19

 set forth in Title 31, united states code, section 5330, and the regulations prescribed thereunder, including Title 31, Code of Federal Regulations, sections 1010.100(ff)(5) and 1022.380(a)(2); and (ii) otherwise involved the transportation and transmission of funds known to the defendants to have been derived from a criminal offense and intended to be used to promote and support unlawful activity.

40. In furtherance of said conspiracy and to effect the illegal object thereof, the following overt act, among others, was committed in the southern District of New York and elsewhere:

a. From on or about November 29, 2011, up to and including on or about December S, 2011, ARTHUR BUDOVSKY, a/k/a "Arthur Belanchuk," a/k/a "Eric Paltz," the defendant, caused a series of wire transfers, totaling approximately $13.5 million, to be made from Costa Rican bank accounts held by LIBERTY RESERVE, the defendant, through a correspondent bank account in the southern District of New York, to a shell-company bank account in Cyprus controlled by AZZEDDINE EL AMINE, the defendant.