Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 34 of 37
93. Additionally, and in order to maintain their accounts at PayPal and elsewhere, including online cryptocurrency exchanges, Defendants and their co-conspirators purchased and obtained false identification documents, including fake U.S. driver’s licenses. Some false identification documents obtained by Defendants and their co-conspirators used the stolen identities of real U.S. persons, including U.S. persons T.W. and J.W.
94. After opening the accounts at Bank 1 and PayPal, Defendants and their co-conspirators used them to receive and send money for a variety of purposes, including to pay for certain ORGANIZATION expenses. Some PayPal accounts were used to purchase advertisements on Facebook promoting ORGANIZATION-controlled social media accounts. The accounts were also used to pay other ORGANIZATION-related expenses such as buttons, flags, and banners for rallies.
95. Defendants and their co-conspirators also used the accounts to receive money from real U.S. persons in exchange for posting promotions and advertisements on the ORGANIZATION-controlled social media pages. Defendants and their co-conspirators typically charged certain U.S. merchants and U.S. social media sites between 25 and 50 U.S. dollars per post for promotional content on their popular false U.S. persona accounts, including Being Patriotic, Defend the 2nd, and Blacktivist.
All in violation of Title 18, United States Code, Section 1349.
COUNTS THREE THROUGH EIGHT
(Aggravated Identity Theft)
96. Paragraphs 1 through 7, 9 through 27, and 29 through 85, and 89 through 95 of this Indictment are re-alleged and incorporated by reference as if fully set forth herein.
97. On or about the dates specified below, in the District of Columbia and elsewhere,
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