A. THE OBJECT OF THE CONSPIRACY
43. Beginning no later than in or about June 2009, and continuing through at least in or about December 2012, in Los Angeles County, within the Central District of California, and elsewhere, defendants POSSINO, NIX, MENDIRATTA, ANGELASTRI, HARRIS, MOYAL, SCARPELLO, and SPITARI, together with others known and unknown to the Grand Jury, knowingly combined, conspired, and agreed to commit international promotional money laundering, in violation of Title 18, United States Code, Section 1956(a) (2) (A), by transporting, transmitting, and transferring, and attempting to transport, transmit, and transfer, monetary instruments and funds to places inside the United States from and through places outside the United States, with the intent to promote the carrying on of Specified Unlawful Activity.
B. THE MANNER AND MEANS OF THE CONSPIRACY
44. The object of the conspiracy was carried out, and to be carried out, in substance, as follows:
a. In order to promote the carrying on of Specified Unlawful Activity, among other purposes, defendants POSSINO, NIX, MENDIRATTA, ANGELASTRI, HARRIS, MOYAL, and SCARPELLO, and others known and unknown to the Grand Jury, caused monetary transfers from accounts in. Switzerland and Liechtenstein, including accounts in the names of defendant ANGELASTRI, Ebony Finance, Serendipity, Steinhov, and Sula, to accounts in the United States, including accounts in the names of Calbridge Capital, Apache Capital, and FrogAds.
b. Defendants POSSINO, NIX, HARRIS, MOYAL, SCARPELLO, and SPITARI, and others known and unknown to the Grand Jury, used and caused to be used the monies received in the accounts in the names of Calbridge Capital, Apache Capital, and FrogAds for purposes of promoting the carrying on of Specified Unlawful Activity, including promoting and purchasing the stocks of Sport Endurance, FrogAds, and Empire in preparation for and during the manipulation campaigns for those companies.
Extract -
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