Page:US District Court, Southern District of New York.-Liberty Reserve Indictment.pdf/9

 in Malaysia, Russia, Nigeria, and vietnam. The exchangers charged transaction fees for their services, typically amounting to five percent or more of the funds being exchanged. Such fees were much higher than chose charged by mainstream banks or payment processors for comparable money transfers.

19. As set forth above, LIBERTY RESERVE's system was designed so that criminals could effect financial transactions under multiple layers of anonymity and thereby avoid apprehension by law enforcement. Not surprisingly, LIBERTY RESERVE was in fact used extensively for illegal purposes, functioning in effect as the bank of choice for the criminal underworld. LIBERTY RESERVE users routinely established accounts under false names - including such blatantly criminal monikers as "Russia Hackers" and "Hacker Account." Believing themselves to be protected by this anonymity, LIBERTY RESERVE users then engaged in criminal transactions with an impunity that would have been impossible in the legitimate financial system.

20. To further enable the use of LIBERTY RESERVE for criminal activity, its website offered a "shopping cart interface" that "merchant" websites could use to accept LR currency as a form of payment. The "merchants" who accepted LR currency were overwhelmingly criminal in nature. They included,