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 other activity that would leave a centralized financial paper trail.

17. LIBERTY RESERVE’s "exchangers" were third-party entities that maintained direct financial relationships with LIBERTY RESERVE, buying and seiling LR in bulk from LIBERTY RESERVE in exchange for mainstream Currency. The exchangers in turn bought and sold this LR in smaller transactions With and users in exchange for mainstream currency, Thus, in order to fund a LIBERTY RESERVE account, a user was required to transmit mainstream currency in some fashion (through a money remitter for example) to an exchanger. upon receiving the user's payment, the exchanger credited the user's LIBERTY RESERVE account with a corresponding amount of LR, by transferring LR from the exchanger’s LIBERTY RESERVE account to the user's account, similarly, if a LIBERTY RESERVE user wished to withdraw funds from his account, the user was required to transfer LR from his LIBERTY RESERVE account to an exchanger's LIBERTY RESERVE account, and the exchanger then made arrangements to provide the user a corresponding amount of mainstream currency.

18. The LIBERTY RESERVE website recommended a number of "pre-approved" exchangers. These exchangers tended to be unlicensed money transmitting businesses operating without significant governmental oversight or regulation, concentrated