Page:US District Court, Southern District of New York.-Liberty Reserve Indictment.pdf/4

 anonymous and untraceable. The defendants also protected the criminal infrastructure they created by, among other things lying to anti-money laundering authorities in Costa Rica, pretending to shut down LIBERTY RESERVE after learning the Company was being investigated by U.S. law enforcement (only to continue operating the business through a set of shell companies), and moving tens of millions of dollars through shell-company accounts maintained in Cyprus, Russia, Hong Kong China, Morocco, Spain, and Australia, among other places.

9. Through the defendants’ efforts, LIBERTY RESERVE has emerged as one of the principal means by which cyber-criminals around the world distribute, store, and launder the proceeds of their illegal activity. Indeed, LIBERTY RESERVE has become a financial hub of the cyber-crime world, facilitating a broad range of online criminal activity, including credit card fraud identity theft, investment fraud, computer hacking, child pornography, and narcotics trafficking.

10. Because virtually all of LIBERTY RESERVE's business derived from suspected criminal activity, the scope of the defendants’ unlawful conduct is staggering. Estimated to have had more than one million users worldwide, with more than 200,000 users in the united states, LIBERTY RESERVE processed more than 12 million financial transactions annually, with a combined value of more than $l.4 billion. Overall, from 2006 to