Case 1:18-cr-00024-DLF *SEALED* Document 13 Filed 02/12/18 Page 2 of 4
of these accounts using stolen identities, he willfully and intentionally avoided learning about the use of stolen identities.
3. Company 1 required users to submit bank account numbers as a means of verifying a user's identity. To circumvent this requirement, certain users (hereinafter "Users") registered for Company 1's online services with bank account numbers in the names of other people. PINEDO sold Users bank account numbers over the internet to aid and abet, and in connection with, this scheme to defraud Company 1 by means of internet communications in interstate and foreign commerce.
4. After acquiring bank account numbers from PINEDO, Users linked the bank account numbers to their accounts with Company 1 as if they were the real owners of the bank accounts. Company 1 sought to verify the bank account numbers by making de minimus trial deposits into the accounts and asking Users to identity the amount of those trial deposits. PINEDO told Users the amounts of those trial deposits, thereby further aiding the Users in their scheme to circumvent verification processes by Company 1.
5. PINEDO frequently purchased bank account numbers from an individual he knew to be outside the United States. Similarly, based on IP addresses and other information, PINEDO knew that many of the persons to whom he sold bank account numbers were outside the United States.
6. In total, PINEDO knowingly transferred, possessed, and used, without lawful authority, hundreds of bank account numbers to aid and abet, and in connection with, the use of the wires in interstate and foreign commerce to defeat security measures employed by Company l. PINEDO personally collected tens of thousands of dollars, and more than $1,000 during a one-year period, through the sale of these bank account numbers.
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