lim teb tateg ZiBi tritt Qtnurt FOR THE gr NORTHERN DISTRICT OF CALIFORNIA 34 f s 11 Q2 VENUE SAN FRANCISCO A 03 5 3 @859 Rap 0 UNITED STATES OF AMERICA 04 0004 V -- SEALED - BY CQURT ORDER DMITRY DQKUCHAEV a k a Patrick Nagel IGOR SUSHCHIN ALEXSEY VC BELAN a k a Magg and KARIM BARATOV a k a Kay a k a Karim Taloverov a k a Karim Akehmet TokbergenOICR 7 1 0 3 INDICTMENT 18 U S C 1030 b Conspiracy To Commit Computer Fraud And Abuse 18 U S C 1831 a 5 Conspiracy To Commit Economic Espionage 18 U S C 1832 a 5 Conspiracy to Steal Trade Secrets 18 U S C 1831 a 1 - Economic Espionage 18 U S C 1832 a 1 Theft of Trade Secrets 18 U S C 1349 - Conspiracy to Commit Wire Fraud 18 U S C 1030 a 2 C - Unauthorized Access to Protected Computers 18 U S C 1030 a 5 A Damaging Protected Computers 18 U S C 1029 b 2 Conspiracy to Commit Fraud in Connection with Access Devices 18 U S C 1030 a 2 C Unauthorized Access to Protected Computers 18 U S C 1029 a 1 Traf cking in Counterfeit Access Devices 18 U S C 1028A Aggravated Identity Theft 18 U S C 982 a 2 B 1030 i and First Forfeiture Allegation 18 U S C 1834 and 2323 Second Forfeiture Allegation 18 U S C 982 a 2 B and 1029 c 1 C and 28 U S C 2461 c Third Forfeiture Allegation Foreman Filed in open court this 36 day of VF7 BRIAN J STRETCH CABN 163973 United States Attorney UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION UNITED STATES OF AMERICA Plaintiff V DMITRY DOKUCHAEV a k a Patrick Nagel IGOR ALEXSEY BELAN a k a GMagg35 and KARIM BARATOV a k a CKayi a k a Karim Taloverov a k a Karim Akehmet Tokbergenov Defendants The Grand Jury chargesVIOLATIONS 18 U S C 1030 b Conspiracy To Commit Computer Fraud And Abuse 18 U S C 183 Conspiracy To Commit Economic Espionage 18 U S C 1832 a 5 Conspiracy to Steal Trade Secrets 18 U S C 1831 a 1 Economic Espionage 18 U S C 1832 a 1 Theft of Trade Secrets 18 U S C 1349 Conspiracy to Commit Wire Fraud 18 U S C 1030 a 2 C Unauthorized AcceSs to Protected Computers 18 U S C 103 Damaging Protected Computers 18 U S C 1029 b 2 Conspiracy to Commit Fraud in Connection with Access Devices 18 U S C 1030 a 2 C Unauthorized Access to Protected Computers 18 U S C 1029 a 1 - Traf cking in Counterfeit Access Devices 18 U S C 1028A Aggravated Identity Theft 18 U S C 982 a 2 B 1030 i and First Forfeiture Allegation 18 U S C 1834 and 2323 Second Forfeiture Allegation 18 U S C 982 a 2 B and 1029 c l C and 28 U S C 2461 c Third Forfeiture Allegation INDICTMENT At all times relevant to this Indictment unless otherwise stated INDICTMENT INTRODUCTION 1 From at least in or about 2014 up to and including at least in or about December 2016 of cers of the Russian Federal Security Service an intelligence and law enforcement agency of the Russian Federation Russia headquartered in Lubyanka Square Moscow Russia and a successor service to the Soviet Union s Committee of State Security conspired together and with each other to protect direct facilitate and pay criminal hackers to collect information through computer intrusions in the United States and elsewhere The SB of cers defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and others known and unknown to the Grand Jury directed the criminal hackers defendants ALEXSEY BELAN KARIM BARATOV and others known and unknown to the Grand Jury collectively the conspirators to gain unauthorized access to the computers of companies providing webmail and internet-related services located in the Northern District of California and elsewhere to maintain unauthorized access to those computers and to steal information from those computers including information regarding and communications of the providers users 2 In some cases the conspirators sought unauthorized access to information'of predictable interest to the FSB For example as described in more detail below the conspirators sought access to the Yahoo Inc Yahoo email accounts of Russian journalists Russian and US government of cials employees of a prominent Russian cybersecurity company and numerous employees of US Russian and other foreign webmail and internet-related service providers Whose networks the conspirators sought to further exploit 3 In other cases the conspirators sought access to accounts of employees of commercial entities including executives and other managers of a prominent Russian investment banking rm the Russian Financial Firm a French transportation company US nancial services and private equity rms a Swiss bitcoin wallet and banking rm and a US airline 4 One of the criminal hackers BELAN has been the subject of an Interpol Red Notice and listed as one of the Federal Bureau 'of Investigation s Most Wanted hackers since 2012 BELAN resides in Russia within the jurisdiction to arrest and prosecute Rather than arrest him however the FSB of cers used him They also provided him with sensitive FSB law enforcement and intelligence information that would have helped him avoid detection by law enforcement including INDICTMENT 2 45MBinformation regarding FSB investigations of computer hacking and SB techniques for identifying criminal hackers It was BELAN who provided his FSB conspirators including DOKUCHAEV and SUSHCHIN with the unauthorized access to Yahoo s network described above 5 In addition to executing DOKUCHAEV and taskings BELAN leveraged his access to Yahoo s network to enrich himself through an online marketing scheme by manipulating Yahoo search results for erectile dysfunction drugs by searching Yahoo user email accounts for credit card and gift card account numbers and other information that could be monetized and by gaining unauthorized access to the accounts of more than 30 million Yahoo users the contacts of whom were then stolen as part of a spam marketing scheme 6 When the FSB of cers SUSHCHIN and DOKUCHAEV learned that a target of interest had email accounts at webmail providers other than Yahoo including through information gained from the Yahoo intrusion they would task BARATOV to access the target s account at the other providers When BARATOV was successful as was often the case his handling FSB officer DOKUCHAEV paid him a bounty 7 For example SUSHCHIN DOKUCHAEV and BARATOV sought access to the Google Inc Google webmail accounts of a an assistant to the Deputy Chairman of the Russian Federation b an of cer of the Russian Ministry of Internal Affairs 0 a physical training expert working in the Ministry of Sports of a Russian republic and d others including additional examples described below THE DEFENDANTS 8 DMITRY ALEKSANDROVICH DOKUCHAEV also known as Patrick Nagel was a Russian national and resident DOKUCHAEV was an FSB of cer assigned to Second Division of FSB Center 18 also known as the SB Center for Information Security He was an associate of FSB of cer IGOR another supervisory FSB of cer known to the Grand Jury Of cer who was the senior FSB of cial assigned to Center 18 and other FSB of cers knOwn and unknown photograph is attached as Exhibit A INDICTMENT 3 IGOR ANATOLYEVICH SUSHCHIN was a Russian national and resident SUSHCHIN was an FSB of cer and superior within the FSB SUSHCHIN was also an associate of FSB Of cer 3 and other FSB of cers known and unknown SUSHCHIN was embedded as a purported employee and Head of Information Security at the Russian Financial Firm where he monitored the communications of Russian Financial Firm employees although it is unknown to the grand jury whether the Russian Financial Firm knew of his FSB af liation photograph is attached as Exhibit B 10 ALEXSEY ALEXSEYEVICH BELAN also known as Magg was a Russian national and resident He was a criminal hacker and associate of DOKUCHAEV BELAN assisted DOKUCHAEV by carrying out hacking assignments BELAN was indicted in September 2012 in the District of Neyada for computer fraud and abuse and related crimes in connection with his intrusion into the computer systems of a U S e commerce company He was also indicted in June 2013 in the Northern District of California for computer fraud and abuse and related crimes in connection with intrusions at two other U S e-commerce companies He was arrested in 2013 in a European country on a U S provisional arrest warrant but before he could be extradited to the United States he was able to leave that country and return to Russia Currently BELAN is the subj cot of an outstanding Interpol Red Notice requesting that Interpol member nations including Russia arrest and extradite him BELAN is also on the list of Most Wanted hackers and was recently the subject of the December 29 2016 sanctions designation by the President of the United States based at least in part on his signi cant malicious cyber enabled misappropriation of personal identi ers for private nancial gain in relation to the above described criminal charges photograph is attached as Exhibit C 11 KARIM BARATOV also known as Kay Karim Taloverov and Karim Akehmet Tokbergenov was a Canadian national and resident He was a criminal hacker and associate of DOKUCHAEV BARATOV assisted DOKUCHAEV by carrying out his hacking assignments photograph is attached as Exhibit D INDICTMENT 4 COUNT ONE 18 U S C 1030 b Conspiracy to Commit Computer Fraud and Abuse 12 Paragraphs 1 through 11 of this Indictment are hereby re-alleged and incorporated by reference as if set forth in full herein 13 From a date unknown to the Grand Jury but no later than January 2014 and continuing through December 1 2016 in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV ALEXSEY BELAN IGOR SUSHCHIN and KARIM BARATOV did knowingly and willfully conspire and agree with each other and with others knoWn and unknown to the Grand Jury to commit computer fraud and abuse namely a to access computers without authorization and exceed authorized access to computers in the Northern District of California and elsewhere and to thereby obtaininformation from protected computers for the purpose of commercial advantage and private financial gain and in furtherance of a criminal and tortious act in violation of the laws of California including invasion of privacy and where the value of the information did and would if completed exceed $5 000 in Violation of Title 18 United States Code Sections 1030 a 2 C and and b to cause the transmission of programs information codes and commands in the Northern District of California and elsewhere and as a resultof such conduct to cause damage without authorization to protected computers and where the offense did cause and would if completed have caused loss aggregating $5 000 in value to at least one person during a one-year period from a related course of conduct affecting a protected computer and damage affecting at least 10 protected computers during a one year period in violation of 18 U S C 1030 a 5 A and 1030 c 4 B MANNER AND MEANS OF THE CONSPIRACY 14 The conspirators used the following manner and means to accomplish their objectives 15 The conspirators directly and through intermediaries attempted to hide the nature and origin of their internet traffic and reduce the likelihood of detection by victims and law enforcement by INDICTMENT 5 leasing servers in numerous countries including the United States and using other services like virtual private networks 16 The conspirators used numerous email accounts hosted by webmail providers in the United States and elsewhere including Russia which they often registered using false subscriber information 17 In some instances the conspirators used email messages known as spear phishing messages to trick unwilling recipients into giving the co-conspirators access to their computers and accounts Spear phishing messages typically were designed to resemble emails from trustworthy senders and to encourage the recipient to open attached les or click on hyperlinks in the messages Some spear phishing emails attached or linked to les that once opened or downloaded installed malware ma1icious code or pro grams that provided unauthorized access to the recipient s computer a backdoor Other spear phishing emails lured the recipient into providing valid login credentials to his or her account s thereby allowing the defendants to bypass normal authentication procedures 18 In many instances the conspirators engaged in the manual creation of account authentication cookies known as minting to gain unauthorized access to victim webmail accounts Cookies are small les stored on a user s computer by the user s web browser Upon a user s connection to a webmail server the server can read the data in the cookie and obtain information about that speci c user Among other uses cookies enable webmail providers to recognize an account user who had previously logged into his or her account and to allow that user for a speci ed duration to continue to access the account s contents without re-entering his or her password 19 The conspirators frequently sought unauthorized access to the email accounts of close associates of their intended victims including spouses and children to gain additional information about and belonging to their intended victims INDICTMENT 6 The Yahoo Intrusions 20 Yahoo was a webmail provider based in Sunnyvale California which provided internet services including electronic messaging services to more than 1 billion users 21 Beginning no later than 2014 the conspirators stole non-content information regarding more than 500 million Yahoo user accounts as a result of their malicious intrusion The theft of user data was part of a larger intrusion into Yahoo s computer network which continued to and including at least September 2016 As part of this intrusion malicious files and software tools were downloaded onto Yahoo s computer network and used to gain and maintain further unauthorized access to Yahoo s network and to conceal the extent of such access 22 The user data referenced in the preceding paragraph was held in Yahoo s User Database The UDB was and contained proprietary and con dential Yahoo technology and information including among other data subscriber information such as account users names recovery email accounts and phone numbers which users provide to webmail providers such as Yahoo as alternative means of communication with the provider password challenge questions and answers and certain security information associated with the account e the account s nonce further described below Some of the information in the UDB was stored in an form 23 Yahoo used its Account Management Tool to access and edit the information stored in the UDB The AMT allowed Yahoo to manage aspects of its users accounts including to make log and track changes to the account such as password changes The AMT was and contained proprietary and con dential Yahoo technology and information 24 In or around early 2014 the conspirators gained unauthorized access to Yahoo s network and began their reconnaissance After gaining unauthorized access to Yahoo s network BELAN located relevant Yahoo network resources of interest including the UDB and AMT 25 In or around November and December 2014 BELAN stole a backup copy of the UDB as it existed in early November 2014 He removed at least some of the UDB copy to one of the computers under his control the Computer by using the File Transfer Protocol a common means of transferring data between computers INDICTMENT 7 26 Beginning in or around October 2014 and until at least November 2016 the conspirators accessed user account information and contents using a combination of methods including without limitation via unauthorized access to Yahoo s via the minting of authentication cookies on Yahoo s netWork to gainunauthorized access to victim webmail accounts and via the minting of authentication cookies outside Yahoo s network 27 The conspirators minted authentication cookies internally within Yahoo s network while they trespassed on the network In order to mint cookies internally the conspirators caused programs to be loaded onto Yahoo s network and computers without authorization 28 The conspirators also minted authentication cookies externally tie outside Yahoo s network In order to mint cookies externally the conspirators required among other information a value unique to the targeted victim account called a nonce The nonces associated with indiVidual Yahoo user accounts were stored in the UDB and thus when BELAN stole a copy of at least a portion of the UDB in November and December 2014 the defendants obtained the nonces associated with affected user accounts 2 29 Whenever a Yahoo user changed his or her password the nonce associated with the account changed as well As a result comparing the date that victims last changed their passwords to the defendants cookie minting attempts con rms that the conspirators employed the UDB copy that BELAN stole 4 2 the UDB as it existed in early November 2014 to gain unauthorized access to Yahoo user accounts via external cookie minting The conspirators failed to access those accounts whose users had changed their passwords after BELAN stole the UDB copy but they succeeded in accessing those accounts that retained the same passwords in use at the time the conspirators obtained the UDB copy including those accounts for which the user had most recently changed the password immediately prior to theft of the UDB copy 30 The conspirators discussed among themselves how to mint cookies to access Yahoo accounts For example on or about July 20 2015 DOKUCHAEV sent SUSHCHIN a minted cookie for INDICTMENT 8 Loam Yahoo user account a le containing the below screenshot of a cookie manager application and instructions for using the application to access the Yahoo email account foxwafm 95516 53 L7 0 $9 13 jg 1 - 10195 aboutmddons Figure 1 Screenshot of a cookie manager application 31 Both internally and externally minted cookies allowed the conspirators to appear to Yahoo s servers as if the intruder had previously obtained valid access to the associated Yahoo user s account obviating the need to enter a username and password for that account The conspirators utilized cookie minting to access the contents of more than 6 500 Yahoo user accounts 32 The conspirators used their access to the AMT to among other unauthorized actions maintain persistent unauthorized access to some of the compromised accounts 33 The AMT did not permit text searches of underlying data It permitted the conspirators to access information about particular Yahoo user accounts However by combining their control of the stolen UDB copy and access to the AMT the conspirators could for example search the UDB contents to identify Yahoo user accounts for which the user had provided a recovery email account hosted by a speci c company of interest to the conspirators showing that the user was likely an employee of the company of interestmand then use information INDICTMENT 9 from the AMT to gain unauthorized access to the identi ed accounts using the means described in paragraph 26 34 The conspirators used their unauthorized access to Yahoo s network to identify and access accounts of among other victims users af liated with US online service providers including but not limited to webmail providers and cloud computing companies whose account contents could facilitate unauthorized access to other victim accounts Russian journalists and politicians critical of the Russian government Russian citizens and government of cials former of cials from countries bordering Russia and US government of cials including cyber security diplomatic military and White House personnel For example a In or around October 2014 the conspirators sought and DOKUCHAEV later obtained access to an account of a diplomat from a country bordering Russia who was posted in a European country b From at least in or around December 2015 until May 2016 the conspirators sought access to accounts of the former Minister of Economic Development of a country bordering Russia Victim and his wife Victim DOKUCHAEV SUSHCHIN and BELAN worked with SB Of cer 3 to access'Victims A and B s accounts by minting cookies and to share information obtained from those accounts In one instance on or about December 18 2015 FSB Officer 3 provided SUSHCHIN with information regarding a company controlled by Victims A and B On or about December 21 2015 DOKUCHAEV sent a cookie for Victim B s account to SUSHCHIN who then later that day sent DOKUCHAEV a report on Victims A and On or about May 20 2016 BELAN minted a cookie for the same Victim B account 0 In or around December 2015 and January 2016 the conspirators sought access to an account of a Russian journalist and investigative reporter who worked for Kommersant Daily DOKUCHAEV obtained information about the victim s account from the AMT and then obtained full access to the victim user s account by minting cookies on or about December 6 2015 and January 21 2016 INDICTMENT 10 around December 2015 and January 2016 the conspirators sought access to an account of a public affairs consultant and researcher who analyzed Russia s bid for World Trade Organization membership DOKUCHAEV accessed the contents of the victim user s account by minting cookies In or around February 2016 the conspirators sought access to Yahoo accounts of employees of a US cloud storage company s Cloud Computing Company On or about February 26 2016 DOKUCHAEV gained accessed to the Yahoo user accounts of three different of cers of US Cloud Computing Company 1 in each case by minting cookies In or around March 2016 the conspirators sought access to an account of a Russian Deputy Consul General On or about March 19 2016 DOKUCHAEV successfully minted a cookie to gain access to the victim s account In or around April 2016 the conspirators sought access to an account of a senior of cer at a Russian webmail and internet-related services provider the Russian Webmail Provider On or about April 25 2016 DOKUCHAEV successfully minted a cookie to gain access to the victim user s account The conspirators used their unauthorized access to Yahoo s network in order to defraud Yahoo users as well For a period in or around November 2014 at around the same time he was working to provide DOKUCHAEV and SUSHCHIN with access to Yahoo s network BELAN manipulated some of the servers associated with Yahoo s English-language search engine so that when users searched for erectile dysfunction medications they were presented with a fraudulent link created by BELAN When a Yahoo user clicked on that link he or she was taken to the website of a U S -based cloud computing rm U S Cloud Computing Company 2 The Yahoo search engine users were then automatically redirected by malicious code placed by BELAN on the website of US Cloud Computing Company 2 and without themselves taking any additional actions to the website of an online pharmacy com an That online harmac com an s marketin ro ram aid commissions to marketers who successfully drove traf c to its website As a result BELAN was paid for diverting Yahoo search engine users to it INDICTMENT 11 36 Other examples of Yahoo users whose accounts the conspirators targeted and compromised include INDICTMENT a On or about July 11 2015 BELAN gained access to accounts belonging to 14 employees of a Swiss bitcoin wallet and banking rm On or about February 13 2016 one conspirator gained access to an account belonging to a sales manager at a major US nancial company On or about March 30 2016 DOKUCHAEV gained aCcess to an account belonging to a Nevada gaming of cial On or about April 14 2016 BELAN gained access to an account belonging to a senior of cer of a major US airline On or about June 20 2016 a defendant gained access to an account belonging to a Shanghai-based managing director of a US private equity rm On or about October 22 2016 the conspirators gained access to accounts of the Chief Technology Of cer of a French'transportation company The conspirators sought access to accounts of multiple Yahoo users affiliated With the Russian Financial Firm In one instance in or around April 2015 SUSHCHIN ordered DOKUCHAEV to target a number of individuals including a senior board member of the Russian Financial Firm his wife and his secretary and a senior officer of the Russian Financial Firm Corporate Of cer In or around April 2015 the conspirators gained access to a Yahoo account the conspirators mistakenly believed belonged to Corporate Officer 1 In or around October 2015 SUSHCHIN and DOKUCHAEV then developed a spear phishing email to send to Corporate Of cer 1 purporting to originate from the Russian Federal Tax Service in an attempt to gain unauthorized access to another non- Yahoo email account the officer controlled The targeting of the Russian Financial Firm continued into 2016 Speci cally on or about January 13 2016 the conspirators used Yahoo s AMT to access data associated with the account of the above-referenced board member s secretary 12 oo qoxm4n 37 BELAN also stole nancial information from certain Yahoo user accounts for personal gain For example on or about April 26 2015 BELAN searched within a victim user s account for credit card veri cation values cvv numbers As another example on or about June 20 2015 he did the same within a different user account in addition to searching for amex then he moved to another victim account and searched for among other terms visa amex mastercard and credit card then searched for those same terms in yet another user s account on the same day In all BELAN sought nancial information from at least eight Yahoo users accounts that day 7 38 BELAN sought to steal gift card information from victim email accounts as well For example on or about October 8 2016 BELAN searched the email accounts of at least 15_ Yahoo victim users for gift cards including by searching for the email address from which a major US online retailer sent gift cards to its customers 39 In addition BELAN used his access to Yahoo s network to further a spam marketing scheme by minting cookies that enabled access to more than 30 million victim user accounts From at least in or around March 2015 until in or around July 2015 BELAN used a malicious script he placed on Yahoo s network to mint cookies in bulk up to at least tens of thousands of cookies at a time Using computers under his control including the BELAN Computer BELAN minted in bulk cookies that were later used to steal the email contacts of the victim accounts such contacts are valuable to spammers because they permit spammers to send emails purporting to originate from associates or acquaintances of targeted recipients making it more likely the targeted recipient will open the spam email Thousands of the bulk minted cookies were removed from Yahoo s network to the BELAN Computer 40 As they victimized Yahoo the conspirators took steps to conceal their actions from Yahoo and law enforcement For example BELAN downloaded to Yahoo s network from the BELAN Computer a program known as a log cleaner This program sought to remove traces of the intrusion from Yahoo s records logs of network activity to make the conspirators more difficult to track 41 Finally the conspirators used the stolen Yahoo data to compromise related user accounts at Yahoo Google and other webmail providers including the Russian Webmail Provider Among other means they exploited the Yahoo data by searching within victim user accounts fer other Yahoo or non Yahoo accounts controlled by the same victim that the conspirators could later target for unauthorized INDICTMENT 13 access passwords challenge question answers and other information of use to the conspirators For example 3 On or about August 31 2015 BELAN gained access to a Yahoo user account then searched for terms including password and Google and phrases including Goo gle account Apple acCount and itunes account On or about September 29 2015 BELAN gained access to a Yahoo user account controlled by an officer of a U S -based technology and internet related services company the Technology Company and then searched that account for terms and phrases including TechnologyCompany password and Yahoo user Technology Companyjcom The Google and Other Account Intrusions 42 During the same period that DOKUCHAEV SUSHCHIN and BELAN were committing intrusions into the Yahoo computer network and the accounts-of individual Yahoo users DOKUCHAEV and SUSHCHIN were directing BARATOV to access individual accounts provided by Google the Russian Webmail Provider and other webmail providers For example the conspirators sought unauthorized access to the accounts of a b 43 I An assistant to the Deputy Chairman of the Russian Federation A managing director a former sales of cer and a researcher all of whom worked for a major Russian cyber security rm An of cer of the Russian Ministry of Internal Affairs assigned to that Ministry s Department its Bureau of Special Technical Projects which investigates cyber high technology and child pornography crimes A physical training expert working in the Ministry of Sports of a Russian republic and A Russian of cial who was both Chairman of a Russian Federation Council committee and a senior of cial at a major Russian transport corporation In some cases DOKUCHAEV and SUSHCHIN identified target accounts based on information obtained through unauthorized access to Yahoo s network and its users accounts For example on or about October 9 2014 the conspirators accessed records for account INDICTMENT 14 as@yahoo com in the AMT associated with the CEO of a metals industry holding company in a country bordering Russia Using the AMT they changed the Yahoo user s recovery email acCount to an account controlled by then approximately ve minutes later DOKUCHAEV falsely veri ed the change by clicking on an email link automatically generated by Yahoo DOKUCHAEV then changed the account password The next day on or about October 10 2014 DOKUCHAEV asked BARATOV to gain access to the account that had served as recovery email account until change the day before 44 Also on or about October 9 2014 DOKUCHAEV sought unauthorized access to account belonging to a prominent banker and university trustee in a country bordering Russia DOKUCHAEV changed the recovery account to one DOKUCHAEV controlled and changed I the victim account password Then on or about October 10 2014 DOKUCHAEV tasked BARATOV with gaining unauthorized access to ov@gmail corn the account that had served as recovery email account until change the day before 45 In other instances the conspirators used their unauthorized access to Yahoo s network to obtain additional information about individuals who controlled accounts at other webmail providers to I which the conspirators sought unauthorized access For example I A a On or about February 25 2016 the conspirators gained unauthorized access to information in the AMT regarding a Yahoo account belonging to an International Monetary Fund of cial One week later on or about March 2 2016 the conspirators gained access to that account by minting a cookie That same day the conspirators searched within that Yahoo user account for a particular Google account belonging to a managing director of a nance and banking company in a Country bordering Russia Then on or about March 24 2016 DOKUCHAEV tasked BARATOV with gaining unauthorized access to that Google account b In another example on or about March 2 2016 the conspirators searched a Yahoo account belonging to an advisor to a senior of cial in a country bordering Russia for an email account belonging to a prominent business woman from that country Then on or about March 24 2016 DOKUCHAEV tasked INDICTMENT I 5 BARATOV with gaining access to the same searched-for Google account 46 SUSHCHIN also identi ed accounts to target that were associated with the Russian Financial Firm For example in or around April 2015 SUSHCHIN sent DOKUCHAEV a list of email accounts associated with Russian Financial Firm personnel and family members to target including Google accounts During these April 2015 communications SUSHCHIN identi ed a Russian Financial Firm employee to DOKUCHAEV as the main target Also during these April 2015 communications SUSHCHIN forwarded to DOKUCHAEV an email sent by that main target s wife to a number of other Russian Financial Firm employees SUSHCHIN added the cover note this may be of some use In another example between in or about December 2015 and May 2016 SUSHCHIN directed DOKUCHAEV who in turn directed BARATOV to obtain unauthorized access to the Google and other accounts of Victims A and and their family discussed in paragraph 34 b above 47 During the conspiracy DOKUCHAEV tasked BARATOV with obtaining unauthorized access to at least 80 identi ed email accounts including at least 50 identi ed Google accounts 48 BARATOV knowingly and with intent to defraud sought unauthorized access to Google and other accounts on behalf of DOKUCHAEV and SUSHCHIN through techniques such as spear phishing He created and maintained multiple email accounts for the purpose of sending spear phishing emails to Victims that he targeted at DOKUCHAEV and behest 49 When BARATOV successfully obtained unauthorized access to a victim s account he noti ed DOKUCHAEV and provided evidence of that access He then demanded payment generally approximately U S $100 via online payment services 50 Once DOKUCHAEV sent BARATOV a payment BARATOV provided DOKUCHAEV with valid illicitly obtained account credentials permitting DOKUCHAEV SUSHCHIN and others known and unknown to thereafter access the victim s account without further assistance from BARATOV All in violation of Title 18 United States Code Section 103 INDICTMENT 16 COUNT TWO 18 U S C 1831 a 5 Conspiracy to Engage in Economic Espionage 51 Paragraphs 1 through 11 and 14 through 50 of this Indictment are hereby re alleged and incorporated by reference as if set forth in full herein 52 In connection with the management and protection of its user accounts Yahoo developed and maintained proprietary technology that constituted trade secrets as de ned in Title 18 United States Code Section 1839 3 including a Yahoo s UDB and the data therein including user data such as the names of Yahoo users identi ed recovery email accounts and password challenge answers and Yahoo created and controlled data regarding its users accounts b Yahoo 3 AMT its method and manner of functioning and capabilities and the data it contained and provided and c Yahoo s cookie minting source code 5 3 From at least'in or about January 2014 until December 1 2016 in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and ALEXSEY BELAN together with others known and unknown to the Grand Jury knowingly combined conspired and agreed to a Knowingly and without authorization steal appropriate take and by fraud arti ce and deception obtain trade secrets belonging to Yahoo b Knowingly and without authorization copy duplicate alter replicate transmit deliver send communicate and convey trade secrets belonging to Yahoo and c Knowingly receive buy and possess trade secrets belonging to Yahoo knowing the same to have been stolen appropriated obtained and converted without authorization intending and knowing that the offenses would bene t a foreign government namely Russia and a foreign instrumentality namely the FSB in violation of Title 18 United States Code Section 1831 a 1 2 and 3 INDICTMENT 17 54 In furtherance of the conspiracy and to effect its objects DOKUCHAEV SUSHCHIN and BELAN committed the following acts a In or about October 2014 DOKUCHAEV accessed records for user accountsin YahooINDICTMENT AMT On or about November 10 2014 BELAN stole the Yahoo UDB by removing at least a portion of it to the BELAN Computer On or about December 12 2014 DOKUCHAEV minted an unauthorized cookie On or about July 16 2015 BELAN minted in bulk cookies permitting access to at least 17 000 Yahoo user accounts On or about July 20 2015 DOKUCHAEV instructed SUSHCHIN how to use minted cookies to access Yahoo user accounts On or about December 21 2015 DOKUCHAEV minted a cookie for a Yahoo user account and then sent the minted cookie to SUSHCHIN On or about January 13 2016 the conspirators accessed Yahoo s AMT to obtain unauthorized access to data associated with a Yahoo user account On or about March 25 2016 BELAN used a minted cookie to gain access to a Yahoo user s account On or about May 5 2016 DOKUCHAEV sent a minted cookie for a Yahoo user s account to SUSHCHIN I On or about May 10 2016 SUSHCHIN sent DOKUCHAEV screen shots of victim accounts including a Yahoo user s account to Which SUSHCHIN had gained unauthorized access On or about July 25 2016 DOKUCHAEV sent BELAN information regarding SB law enforcement and intelligence investigations and FSB tactics including its use of informants to target hackers Whose dif cult-to-trace computer intrusion infrastructure made other means of surveillance more dif cult All in violation of Title 18 United States Code Section 1831 a 5 18 COUNT THREE 18 U S C 1832 a 5 Conspiracy to Commit Theft of Trade Secrets 55 Paragraphs 1 through 11 14 through 50 52 and 54 of this Indictment are hereby re- alleged and incorporatedrby reference as if set forth in full herein 56 From at least in or about January 2014 until December 1 2016 in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and ALEXSEY BELAN together with others known and unknown to the Grand Jury knowingly combined conspired and agreed to a Knowingly and without authorization steal appropriate take and by fraud artifice and deception obtain trade secrets belonging to Yahoo that were related to a product or service used in and intended to be used in interstate and foreign commerce b Knowingly and without authorization copy duplicate alter replicate transmit deliver send communicate and convey trade secrets belonging to Yahoo that were related to a product or service used in and intended to be used in interstate and foreign commerce and c Knowingly receive buy and possess trade secrets belonging to Yahoo that were related to a product or service used in and intended to be used in interstate and foreign commerce knowing the same to have been stolen appropriated obtained and converted without authorization intending to convert those trade secrets to the economic bene t of someone other than Yahoo and intending and knowing that the offense wouldinjure Yahoo in violation of Title 18 United States Code Section 1832 a 1 2 and 3 i 5 7 In furtherance of the conspiracy and to effect its objects conspirators committed the overt acts alleged in paragraph 54 All in violation of Title 18 United States Code Section 1832 a 5 INDICTMENT 9 COUNTS FOUR THROUGH SIX 18 U S C 1831 a 1 and 4 Economic Espionage 58 Paragraphs 1 through 11 14 through 50 52 and 54 of this Indictment are hereby re- alleged and incorporated by reference as if set forth in full herein 59 In or about the dates set forth below in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and ALEXSEY BELAN knowingly stole and withbut authorization appropriated took and concealed and by fraud arti ce and deception obtained a trade secret belonging to Yahoo and attempted to do so intending and knowing that the offense would bene t a foreign government speci cally Russia and a foreign instrumentality specifically the FSB COUNT IN OR ABOUT NATURE OF ECONOMIC ESPIONAGE FOUR November December 2014 Theft of at least a portion of Yahoo s UDB FIVE October 2014-March 2016 Theft of information regarding the functioning of the Yahoo AMT SIX August 2015 - Theft of Yahoo cookie minting source code All in violation of Title 18 United States Code Sections 1831 a 1 and 4 and 2 COUNT SEVEN THROUGH NINE 18 U S C 1832 a 1 Theft of Trade Secrets 60 Paragraphs 1 through 11 14 through 50 52 and 54 of this Indictment are hereby re- alleged and incorporated by reference as if set forth in full herein 61 In or about the dates set forth below in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV ALEXSEY BELAN and IGOR SUSHCHIN knowingly stole and without authorization appropriated took and concealed and by fraud arti ce and deception obtained a trade secret belonging to Yahoo and attempted to do so which was related to a product or service used in and intended to be used in interstate and foreign commerce intending to convert that trade secret to the economic bene t of someone other than Yahoo and intending and INDICTMENT 20 knowing that the offense would injure Yahoo COUNT IN OR ABOUT TRADE SECRET THEFT SEVEN November-December 20M Theft of at least a portion of Yahoo s UDB EIGHT October 2014-March 2016 Theft of information regarding the functioning of the Yahoo AMT NINE August 2015 Theft of Yahoo cookie minting source code All in violation of Title 18 United States Code Sections 1832 a 1 and 2 COUNT TEN 18 U S C 1349 Conspiracy to Commit Wire Fraud 62 Paragraphs 1 through 11 14 through 50 and 54 of this Indictment are hereby reualleged and incorporated by reference as if set forth in full herein 63 From at least in or about January 2014 until December 1 2016 in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and ALEXSEY BELAN together with others known and unknown to the Grand Jury conspired to devise a scheme and artifice to defraud and to obtain property from Yahoo and Yahoo users by means of materially false and fraudulent pretenses representations and promises and did knowingly transmit and cause to be transmitted by means of wire communication in interstate and foreign commerce writings signs signals pictures and sounds namely transmitting malicious computer code illicitly obtained credentials and fraudulent messages for the purpose of executing and attempting to execute the scheme and arti ce 64 Speci cally DOKUCHAEV SUSHCHIN and BELAN conspired to devise a scheme whereby BELAN gained unauthorized access to Yahoo s network among other means by stealing and employing Yahoo employee credentials It was further part of the scheme that BELAN provided access to Yahoo s network to DOKUCHAEV and SUSHCHIN who with BELAN stole created and employed account credentials including minted authentication cookies to obtain unauthorized access to Yahoo data and user accounts 65 DOKUCHAEV SUSHCHIN and BELAN thereby fraudulently obtained property from Yahoo and Yahoo users accounts including among other items non-public information of value to each of the conspirators gift card numbers redeemable at online merchants access to payment accounts INDICTMENT 21 4ssuch as PayPal and Western Union accounts information about credit card numbers and the contacts of Yahoo users 66 In furtherance of the scheme to defraud BELAN also manipulated Yahoo search engine code for personal nancial gain All in violation of Title 18 United States Code Section 1349 COUNTS ELEVEN THROUGH THIRTEEN 18 U S C 103 Unauthorized Access to Protected Computers 67 Paragraphs 1 through 11 14 through 50 and 54 of this Indictment are hereby re alleged and incorporated by reference as if set forth in full herein 68 On or about the dates set forth below in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and ALEXSEY BELAN intentionally and without authorization attempted to access and did access a protected computer belonging to Yahoo and thereby obtained information for commercial advantage and private nancial gain obtained information in furtherance of criminal and tortious acts in violation of the laws of California including invasion of privacy and obtained information valued in excess of $5 000 COUNT ON OR ABOUT NATURE OF ACCESS ELEVEN September 2014 Accessing and scanning of Yahoo s corporate network om a Yahoo server and the theft of information regarding Yahoo s network architecture TWELVE November 10 2014 Accessing of Yahoo s corporate network and the theft of at least a portion of Yahoo s UDB THIRTEEN December 12 2014 Accessing of Yahoo s corporate network and theft of at least a portion of Yahoo s UDB All in violation of Title 18 United States Code Sections 103 and 2 INDICTMENT 22 COUNTS FOURTBEN THROUGH SEVENTEEN 18 U S C 1030 a 5 A Damaging Protected Computers 69 Paragraphs 1 through 11 14 through 50 and 54 of this Indictment are hereby re alleged and incorporated by reference as if set forth in full herein 70 On or about the dates set forth below in the Northern District of California and elsewhere the defendants I DMITRY DOKUCHAEV IGOR SUSHCHIN and ALEXSEY BELAN knowingly attempted to cause and did cause the transmission of a programyinformation code and command and as a result of such conduct would and did intentionally cause damage without authorization to at least ten protected computers during a one-year period and causing more than $5 000 in loss in one year COUNT ON OR ABOUT DAMAGING ACT OURTEEN October 30 2014 Placement of malicious code on Yahoo s network to provide a means of facilitating the conspirators future access to Yahoo s servers FIFTEEN November 10 2014 Modi cation of code on Yahoo s system to direct certain Yahoo search engine users to an online pharmacy SIXTEEN June 8 2015 through July Placement of a malicious script onto Yahoo s network to 16 2015 - internally mint cookies The results of this script cookies that would allow access to victims' accounts were then ex ltrated SEVENTEEN August 13 2015 Placement of a new script used to internally mint cookies onto Yahoo s network All in yiolation of Title 18 United States Code Sections 1030 a 5 A 1030 c 4 B and 2 INDICTMENT 23 OONON COUNTS EIGHTEEN THROUGH TWENTY-FOUR l8 U S C 1030 a 2 C Unauthorized Access to Protected Computers 71 Paragraphs 1 through 11 14 through 50 and 54 of this Indictment are hereby re-alleged and incorporated by reference as if set forth in full herein 72 On or about the dates set forth below in the Northern District of California and elSewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and ALEXSEY BELAN intentionally and Without authorization attempted to access and did access a protected computer belonging to Yahoo and thereby obtained and attempted to obtain information for commercial advantage and private nancial gain information in furtherance of criminal and tortious acts in violation of the laws of California including invasion of privacy and information valued in excess of $5 000 COUNT ON OR ABOUT NATURE OF ACCESS EIGHTEEN April 16 2016 BELAN accessed using a fraudulently minted cookie NINETEEN February 26 2016 DOKUCHAEV accessed using a fraudulently minted cookie TWENTY March 30 2016 DOKUCHAEV accessed re4@yahoo com using a fraudulently minted cookie TWENTY-ONE May 17 2016 BELAN accessed using a auduiently minted cookie May 18 2016 BELAN accessed using a fraudulently minted cookie TWENTY-THREE March 3 0 2016 DOKUCHAEV accessed feld@yahoo com using a fraudulently minted cookie TWENTY-FOUR March 30 2016 DOKUCHAEV accessed rosa@yahoo com using a fraudulently minted cookie All in violation of Title'l8 United States Code Sections 103 and 2 COUNTS TWENTY-F IVE THROUGH THIRTY-SIX 18 U S C 1029 a 1 Counterfeit Access Devices 73 Paragraphs 1 through 11 14 through 50 and 54 of this Indictment are hereby re alleged and incorporated by reference as if set forth in full herein IND 24 about the dates set'forth below in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and ALBXSEY BELAN did knowingly and with intent to defraud produce use and traf c in at least one counterfeit access device and attempted to do so COUNT ON OR ABOUT COUNTERFEIT ACCESS DEVICE July 16 2015 BELAN minted at least 17 000 cookies TWENTY-SIX July 20 2015 DOKUCHAEV sent SUSHCHIN a minted cookie for TWENTY-SEVEN September 9 2015 DOKUCHAEV produced and used a minted cookie to gain unauthorized access to account TWENTY-EIGHT September 29 2015 BELAN produced and used a minted cookie to gain unauthorized access to account WENTY-NINE September 29 2015 BELAN produced and used a minted cookie to gain unauthorized access to account THIRTY September 29 2015 BELAN produced and used a minted cookie to gain unauthorized access to account THIRTY-ONE September 29 2015 BELAN produced and used a minted cookie to gain unauthorized access to account THIRTY-TWO September 29 2015 BELAN produced and used a minted cookie to gain unauthorized access to account December 21 2015 DOKUCHAEV sent SUSHCHIN a minted cookie for THIRTY-FOUR April 25 2016 DOKUCHAEV produced and used a minted cookie to gain unauthorized access to account THIRTY-F IVE April 25 2016 DOKUCHAEV produced and used a minted cookie to gain unauthorized access to account THIRTY-SIX May 5 2016 DOKUCHAEV sent SUSHCHIN a minted cookie for All in Violation of Title 18 'United States Code Sections 1029 a 1 1029 b l and 2 COUNT THIRTY-SEVEN 18 U S C 1029 a 4 Device Making Equipment 75 Paragraphs 1 through 11 14 through 50 and 54 of this Indictment are hereby re-alleged and incorporated by reference as if set forth in full herein 76 From in or about December 2015 until in or about March 2016 in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and ALEXSEY BELAN INDICTMENT 25 did knowingly and with intent to defraud produce traf c in have control and custody of and possess device-making equipment and attempted to do so to wit tools and software that could be and were used to mint unauthorized cookies permitting unauthorized access to Yahoo user accounts as alleged in paragraph 74 All in violation of Title 18 United States Code Sections 1029 a 4 and 2 COUNT l8 U S C 1029 b 2 - Conspiracy to COmmit Fraud in Connection with Access Devices 77 Paragraphs 1 through 11 14 through 50 and 54 and the factual allegations set forth in paragraph 75 of this Indictment are hereby re alleged and incorporated by reference as if set forth in full herein 78 From at least in or about January 2014 until December 1 2016 in the Northern District of California and elsewhere the defendants I DMITRY DOKUCHAEV IGOR SUSHCHIN and KARIM BARATOV and others known and unknown knowingly conspired combined and agreed to and did with intent to defraud in an offense affecting interstate and foreign commerce a traf c in and use at least one unauthorized access device during a one-year period to obtain something of value aggregating at least $1 000 during that period in violation of Title 18 United States Code Section 1029 a 2 and b effect transactions with at least one access device issued to another person to receive payment and another thing of value during a one-year period the aggregate value of which was at least $1 000 in violation of Title 18 United States Code Section 1029 a 5 79 Speci cally BARATOV sought and gained unauthorized access to Google and other webmail provider accounts as requested by DOKUCHAEV sometimes after discussions with SUSHCHIN BARATOV provided the means of unauthorized access in the form of valid but illicitly obtained passwords to DOKUCHAEV DOKUCHAEV then paid BARATOV for providing DOKUCHAEV with such information thereby enabling unauthorized access to the requested INDICTMENT 26 email accounts In total DOKUCHAEV paid BARATOV money and other things of value aggregating at least $1 000 for unauthorized email account access during a one-year period from April 17 2015 through April 17 2016 80 OVERT ACTS In furtherance of the conspiracy and to effect its illegal objects BARATOV DOKUCHAEV and SUSHCHIN committed the following acts INDICTMENT a On or about October 10 2014 DOKUCHAEV sent BARATOV a request for unauthorized access to as@gmail com and ov@gmai1 com On or about October 10 2014 DOKUCHAEV sent BARATOV a request for unauthorized access to more than 30 Google accounts not including the two described in the preceding paragraph On or about December 26 2014 BARATOV sent DOKUCHAEV the password for 17@grnail con1 to which account DOKUCHAEV had tasked BARATOV to gain unauthorized access On or about January 2 2015 BARATOV sent DOKUCHAEV the password for 2011@gmail com to which account DOKUCHAEV had tasked BARATOV to gain unauthorized access On or about July 6 2015 BARATOV sent DOKUCHAEV the password for to which account DOKUCHAEV had tasked BARATOV to gain unauthorized access On or about August 1 2015 BARATOV sent DOKUCHAEV a second password for an account for which BARATOV had sent DOKUCHAEV a password on or about January 2 2015 and to which account DOKUCHAEV had tasked BARATOV to gain unauthorized access On or about September 30 2015 BARATOV sent DOKUCHAEV the password for to which account DOKUCHAEV had tasked BARATOV to gain unauthorized access 27 4h Icnm 10about November 16 2015 DOKUCHAEV sent BARATOV a request for unauthorized access to br@gmai1 com and ov@gmail com i On or about November 17 2015 BARATOV sent DOKUCHAEV the password for to which account DOKUCHAEV had tasked BARATOV to gain unauthorized access j On or aboutNovernber 17 2015 DOKUCHAEV paid BARATOV US $104 20 k On or about December 3 2015 BARATOV sent DOKUCHAEV the password for 3 @gmail com to which account DOKUCHAEV had tasked BARATOV to gain unauthorized access I 1 On or about March 24 2016 DOKUCHAEV sent BARATOV a request for unauthorized access to On or about March 25 2016 BARATOV sent DOKUCHAEV the password for to which account DOKUCHAEV had tasked BARATOV to gain unauthorized access All in Violation of Title 18 United States Code Sections 1029 b 2 COUNT THIRTY-NINE 18 U S C 1349 Conspiracy to Commit Wire Fraud 81 Paragraphs 1 through 11 14 through 50 54 and 80 and the factual allegations set forth in paragraph 74 of this Indictment are hereby re-alleged and incorporated by reference as if set forth in full herein 82 From at least in or about January 2014 until December 1 2016 in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV IGOR SUSHCHIN and KARIM BARATOV together with others known and unknown to the Grand Jury conspired to devise a scheme and arti ce to defraud and to obtain property from Google account users by means of materially false and fraudulent pretenses representations and promises and did knowingly transmit and cause to be transmitted by means of wire communication in interstate and foreign commerce writings signs signals pictures and INDICTMENT 2 8 -28 sounds namely transmitting malicious computer code illicitly obtained credentials and fraudulent messages for the purpose of executing and attempting to execute the scheme and arti ce in violation of Title 18 United States Code Section 1343 83 Speci cally DOKUCHAEV and SUSHCHIN identi ed email accounts to which they wanted access DOKUCHAEV then directed attempt to gain unauthorized access to at least 80 email accounts including at least 50 Google accounts BARATOV attempted to obtain access I credentials for the accounts through spear phishing BARATOV when successful sent DOKUCHAEV the passwords for the accounts 84 Upon successfully gaining the credentials for a tasked account BARATOV informed DOKUCHAEV thathe could be paid for his work in Russian rubles US dollars Ukrainian or Euros through online payment services DOKUCHAEV then paid BARATOV using these means All in violation'of Title 18 United States Code Section 1349 COUNTS FORTY THROUGH FORTY-SEVEN 18 U S C 1028A a 1 Aggravated Identity Theft 85 Paragraphs 1 through 50 and 80 of this Indictment are hereby re alleged and incorporated by reference as if set forth in full herein '86 On or about the dates set forth below in the Northern District of California and elsewhere the defendants DMITRY DOKUCHAEV and KARIM BARATOV during and in relation to the crimes of Conspiracy to Commit Computer Fraud in violation of 18 U S C Section 1030 b Unauthorized Access to Computers in violation of 18 U S C Section 103 Conspiracy to Commit Fraud and Related Activity in Connection with Access Devices in violation of 18 U S C Section 1029 b 2 and Conspiracy to Commit Wire Fraud in violation of 18 U S C Section 1349 did knowingly transfer possess and use without lawful authority the means of identi cation of another person COUNT ON OR ABOUT IDENTIFICATION OF ANOTHER PERSON ORTY December-26 2014 BARATOV sent DOKUCHAEV the password and email address for 17@gmail com FORTY-ONE January 2 2015 BARATOV sent DOKUCHAEV the password and email INDICTMENT 29 address for FORTY-TWO July 6 2015 BARATOV sent DOKUCHAEV the password and email address for FORTY-THREE August 1 2015 BARATOV sent DOKUCHAEV the password and email address for September 30 2015 BARATOV sent DOKUCHAEV the password and emaii address for IVE November 17 2015 BARATOV sent DOKUCHAEV the password and emaii address for FORTY-SIX December 3 2015 BARATOV sent DOKUCHAEV the password and email address for March 25 2016 BARATOV sent DOKUCHAEV the password and email address for All in violation of Title 18 United States Code Sections 1028A a 1 and 2 and Title 28 United States Code Section 3238 FIRST FORFEITURE l8 U S C 982 a 2 B '1030 i and 87 The allegations contained in paragraphs one to eleven and Counts One and Eleven through Twenty-F our are hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to Title 18 United States Code Sections 982 a 2 B and 1030 i and 88 Upon conviction of any of the offenses in violation of Title 18 United States Code Section 1030 as set forth in Counts One and Eleven through Twenty Four of this Indictment defendants DMITRY DOKUCHAEV ALEXSEY BELAN IGOR SUSHCHIN and KARIM BARATOV shall forfeit to the United States of America a pursuant to Title 18 United States Code Sections any property constituting or derived from proceeds obtained directly or indirectly as a result of said violations and b pursuant to Title 18 United States Code Sections 1030 i and any property constituting or derived from proceeds obtained directly or indirectly as a result of said violations and any property used to commit or facilitate the commission of said violation or conspiracy thereto 89 The property subject to forfeiture shall include but not be limited to the following INDICTMENT 30 All funds which constitute proceeds that are held on deposit in PayPal account number held by BARATOV in the name of Elite Space Corporation b All funds which constitute proceeds that are held on deposit in PayPal account number 39 held by c a grey Aston Martin DB8 license plate identi cation and d a black Mercedes Benz C54 license plate identi cation 90 If as a result of any act or omission of the defendants any of said property a cannot be located upon the exercise of due diligence b has been transferred or sold to or deposited with a third person 0 has been placed beyond the jurisdiction of the Court 1 has been substantially diminished in value or c has been commingled with other property which without dif culty cannot be subdivided any and all interest defendants have in any other property not to exceed the value of the above forfeitable property including but not limited to a grey Aston Martin DB8 license plate identi cation and a black Mercedes Benz C54 license plate identification shall be forfeited to the United States pursuant to Title 21 United States Code Section 85 3 p and as incorporated in Title 28 United States Code Sections 2323 b SECOND FORFEITURE ALLEGATION 18 U S C 1834 and 2323 91 The allegations contained in paragraphs one to eleven and Counts Two through Nine are hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to Title 18 United States Code Sections 1834 and 2323 92 Upon conviction of any of the offenses in violation of Title 18 Unite States Code Section 1030 as set forth in Counts Two through Nine of this Indictment defendants DMITRY DOKUCHAEV ALEXSEY BELAN and IGOR SUSHCHIN shall forfeit to the United States of America pursuant to Title 18 United States Code Sections 1834 and 2323 any property used or intended to be used in any manner or part to commit or facilitate the INDICTMENT 3 1 ooqoxm-offenses and any propeity constituting or derived from the proceeds obtained directly or indirectly as a result of said offenses 93 The property subject to forfeiture shall include but not be limited to all funds which constitute proceeds that are held on deposit in PayPal account number 9 held by DOKUCHAEV 94 if as a result of any act or omission of the defendants any of said property a cannot be located upon the exercise of due diligence b has been transferred or sold to or deposited with a third person 0 has been placed beyond the jurisdiction of the Court 1 has been substantially diminished in value or c has been commingled with other property which without difficulty cannot be subdivided any and all interest defendants have in any-other property not to exceed the value of the above forfeitable property including but not limited to a grey Aston Martin DB8 license plate identi cation and a black Mercedes Benz C54 license plate identification shall be forfeited to the United States pursuant to Title 21 United States Code Section 853 p and as incorporated in Title 28 United States Code Sections 2323 b THIRD FORFEITURE ALLEGATION 18 U S C 982 a 2 B and 1029 c 1 C and 28 U S C 2461 c 95 The allegations contained in paragraphs one to eleven and Counts Ten and Twenty-Five through Thirty-Eight are hereby re alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to Title 18 United States Code Sections and 1029 c l C and Title 28 United States Code Section 2461 0 96 Upon conviction of any of the offenses in violation of Title 18 United States Code Sections 1029 and 1349 as set forth in Counts Ten and Twenty-Five through Thirty-Eight of this Indictment defendants DMITRY DOKUCHAEV ALEXSEY BELAN IGOR SUSHCHIN and KARIM BARATOV INDICTMENT 32 shall forfeit to the United States of America a 97 98 d 6 pursuant to Title 18 United States Code Section 981 a 1 C and Title 28 United States Code Section 2461 0 any property real or personal which constitutes or is derived from proceeds traceable to these violations pursuant to Title 18 United States Code Section any property constituting or derived from proceeds obtained directly or indirectly as a result of these violations pursuant to Title 18 United States Code Section 1029 c 1 C any personal property used or intended to be used to commit a violation of Title 18 United States Code SectiOn 1 029 The property subject to forfeiture shall include but not be limited to the following All funds which constitute proceeds that are held on deposit in PayPal account number held by BARATOV in the name of Elite Space Corporation All funds which constitute proceeds that are held on deposit in PayPal account number held by a grey Aston Martin DBS license plate identi cation and a black Mercedes Benz C54 license plate identi cation If as a result of any act or omission of the defendants any of said property cannot be located upon the exercise of due diligence has been transferred or sold to or deposited with a third person has been placed beyond the jurisdiction of the Court has been substantially diminished in value or has been commingled with other property which without dif culty cannot be subdivided any and all interest defendants have in any other property not to exceed the value of the above forfeitable property including but not limited to a grey Aston Martin DB S license plate identification INDICTMENT 33 black Mercedes Benz C54 license plate identi cation shall be forfeited to the United States pursuant to Title 21 United States Code Section 853 p and as incorporated in Title 28 United States Code Sections 2461 0 DATED $1 ag 7 A TRUE BILL BRIAN J STRETCH United States Attorney 62 5mm BARBARA J Chief Criminal Division Approved as to form AUSA John I NSD Trial Att Scott McCulloch NSD Cyber nsel Christopher Ott INDICTMENT 34 INDICTMENT Exhibit A 35 INDICTMENT Exhi it INDICTMENT 37 Exhibit 28 INDICTMENT Exhibit 38                     National Security Archive    Suite 701  Gelman Library  The George Washington University    2130 H Street  NW  Washington  D C  20037    Phone  202 994‐7000  Fax  202 994‐7005  nsarchiv@gwu edu