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OneCoin Konstantin Ignatov Plea Agreement
For 5K Letter Published By Inner City
Press Here
By Matthew
Russell Lee, Patreon Thread, Plea
SDNY COURTHOUSE,
Nov 12 – After OneCoin's
Konstantin Ignatov got a stay
of the civil case against him,
his criminal case was said to
have been kicked down the road
for at least another two
months.
It was a
productive two months, at
least for the U.S. Attorney's
Office.
Now on November
12 Inner City Press has
belatedly obtained and is now
putting online here,
on Scribd, Konstantin
Ignatov's plea agreement,
including "On the
understandings specified
below, the Office of the
United States Attorney for the
Southern District of New York
(“this Office”) will accept a
guilty plea from Konstantin
Ignatov (the “defendant”) to
the above-referenced
four-count Superseding
Information (the
“Information"). Count
One of the Information charges
the defendant with conspiracy
to commit wire fraud, from in
or about 2016, up to and
including in or about 2019, in
violation of Title 18, United
States Code, Section 1349.
Count One carries a maximum
sentence of 20 years
imprisonment; a maximum term
of three years' supervised
release; a maximum fine
pursuant to Title 18, United
States Code, Section 3571 of
the greatest of $250,000,
twice the gross pecuniary gain
derived from the offense, or
twice the gross pecuniary loss
to persons other than the
defendant; and a mandatory
$100 special assessment.
Count Two of the Information
charges the defendant with
wire fraud, from in or about
2016, up to and including in
or about 2019, in violation of
Title 18, United States Code,
Sections 1343 and 2. Count Two
carries a maximum sentence of
20 years' imprisonment; a
maximum term of three years'
supervised release; a maximum
fine pursuant to Title 18,
United States Code, Section
3571 of the greatest of
$250,000, twice the gross
pecuniary gain derived from
the offense, or twice the
gross pecuniary loss to
persons other than the
defendant; and a mandatory
$100 special assessment.
Count Three of the Information
charges the defendant with
conspiracy to commit money
laundering, from in or about
2016, up to and including in
or about 2019, in violation of
Title 18, United States Code,
Section 1956(h). Count Three
carries a maximum sentence of
20 years' -
- - - Page
2 imprisonment; a
maximum term of three years'
supervised release; a maximum
fine pursuant to Title 18,
United States Code, Section
1956(a)(1) of the greatest of
$500,000, or twice the value
of the property involved in
the transaction, and pursuant
to Title 18, United States
Code, Section 1956(a)(2) of
$500,000 or twice the value of
the monetary instrument or
funds involved in the
transportation, transmission,
or transfer, whichever is
greatest; and a mandatory $100
mandatory special
assessment. Count Four
of the Information charges the
defendant with conspiracy to
commit bank ud, in violation
of Title 18, United States
Code, Sections 1349. Count
Four carries a maximum
sentence of 30 years'
imprisonment; a maximum term
of five years supervised
release; a maximum fine,
pursuant to Title 18, United
States Code, Section 3571 of
$1,000,000, twice the gross
pecuniary gain derived from
the offense, or twice the
gross pecuniary loss to
persons other than the
defendant resulting from the
offense; and a $100 mandatory
special assessment. The
total maximum sentence of
incarceration for the charges
set forth in the Information
is 90 years'
imprisonment. It is
further understood that the
defendant shall make
restitution in an amount to be
specified by the Court in
accordance with 18 U.S.C. $$
3663, 3663A, and 3664. This
amount shall be paid according
to a plan established by the
Court. The defendant
hereby admits the forfeiture
allegations with respect to
Counts One, Two, and Four of
the Information, and agrees to
forfeit to the United States,
(i) pursuant to Title 18,
United States Code, Sections
981(a)(1)(C) and 982(a)(2)(A),
and Title 28, United States
Code, Section 2461, any and
all property, real and
personal, that constitutes or
is derived from proceeds
traceable to the commission of
the offenses alleged in Counts
One, Two, and Four of the
Information that the defendant
personally obtained; and (2)
pursuant to Title 18, United
States Code, Section
982(a)(1), any and all
property, real and personal,
involved in the offense
alleged in Count Three of the
Information, and any property
traceable to such property,
including but not limited to a
sum of money in United States
currency representing the
amount of property involved in
said offense. It is
understood that the defendant
(a) shall truthfully and
completely disclose all
information with respect to
the activities of himself and
others concerning all matters
about which this Office
inquires of him, which
information can be used for
any purpose; (b) shall
cooperate fully with this
Office, the Federal Bureau of
Investigation (“FBI"), the
Internal Revenue Service
("'IRS”), and any other law
enforcement agency designated
by this Office; (c) shall
attend all meetings at which
this Office requests his
presence; (d) shall provide to
this Office, upon request, any
document, record, or other
tangible evidence relating to
matters about which this
Office or any designated law
enforcement agency inquires of
him; (e) shall truthfully
testify before the grand jury
and at any trial and other
court proceeding with respect
to any matters about which may
request his testimony; (f)
shall bring to this Office's
attention all crimes which he
has committed, and all
administrative, civil, or
criminal proceedings,
investigations, or
prosecutions in which he has
been or is a subject, target,
party, or witness; and, (g)
shall commit no further crimes
whatsoever. Moreover, any
assistance the defendant may
provide to federal
criminal
2019.04.05 Page 3
investigators shall be
pursuant to the specific
instructions and control of
this Office and designated
investigators. It is
understood that this Office
cannot, and does not, agree
not to prosecute the defendant
for criminal tax violations,
if any. However, if the
defendant fully complies with
the understandings specified
in this Agreement, no
testimony or other information
given by him (or any other
information directly or
indirectly derived therefrom)
will be used against him in
any criminal tax prosecution.
Moreover, if the defendant
fully complies with the
understandings specified in
this Agreement, he will not be
further prosecuted criminally
by this Office for any crimes,
except for criminal tax
violations, related to his
participation in: (1) an
international cryptocurrency
fraud scheme known as
“OneCoin” (the “OneCoin
Scheme"), from in or about
2016, up to and including in
or about 2019, as charged in
Counts One and Two of the
Information; (2) a conspiracy
to defraud banks and other
financial institutions
worldwide by causing them to
transfer proceeds of the
OneCoin Scheme by
misrepresenting and omitting
material facts to those banks
and financial institutions,
from in or about 2016, up to
and including in or about
2019, as charged in Count Four
of the Information; and (3) a
conspiracy to launder criminal
proceeds derived from the
OneCoin Scheme, and to
transfer funds internationally
to promote the OneCoin Scheme,
from in or about 2016, up to
and including in or about
2019, as charged in Count
Three of the Information; to
the extent that he has
disclosed such participation
to this Office as of the date
of this Agreement. It is
understood that Ignatov's
truthful cooperation with this
Office is likely to reveal
activities of individuals who
might use violence, force, and
intimidation against Ignatov,
his family, and loved ones.
Should Ignatov's cooperation
present a significant risk of
physical harm, this Office,
upon the written request of
Ignatov, will take steps that
it determines to be reasonable
and necessary to attempt to
ensure his safety and that of
his family and loved ones.
These steps may include
application to the Witness
Security Program of the United
States Marshals Service,
whereby Ignatov, his family,
and loved ones, if approved,
could be relocated under a new
identity It is understood,
however, that the Witness
Security Program is under the
direction and control of the
United States Marshals Service
and of the Office of
Enforcement Operations of the
Department of Justice, not of
this Office. It is
understood that this Agreement
does not bind any federal,
state, or local prosecuting
authority other than this
Office. This Office will,
however, bring the cooperation
of the defendant to the
attention of other prosecuting
offices, if requested by
him. It is understood
that the sentence to be
imposed upon the defendant is
within the sole discretion of
the Court. This Office cannot,
and does not, make any promise
or representation as to what
sentence the defendant will
receive, and will not
recommend any specific
sentence to the Court.
However, this Office will
inform the Probation Office
and the Court of (a) this
Agreement; (b) the nature and
extent of the defendant's
activities with respect to
this case and all other
activities of the defendant
which this Office deems
relevant to sentencing; and
(c) the nature and extent of
the defendant's cooperation
with this Office. In so doing,
this Office may use any
information it deems relevant,
including information provided
by the defendant both prior to
and subsequent to the signing
of this Agreement. In
addition, if this Office
determines that the defendant
has provided substantial
assistance in an investigation
or prosecution, and if he has
fully complied with the
2019.04.05 Page 4
understandings specified in
this Agreement, this Office
will file a motion, pursuant
to Section 5K1.1 of the
Sentencing Guidelines,
requesting the Court to
sentence the defendant in
light of the factors set forth
in Section 5K1.1(a)(1)-(5). It
is understood that, even if
such a motion is filed, the
sentence to be imposed on the
defendant remains within the
sole discretion of the Court.
Moreover, nothing in this
Agreement limits this Office's
right to present any facts and
make any arguments relevant to
sentencing to the Probation
Office and the Court, or to
take any position on
post-sentencing motions. The
defendant hereby consents to
such adjournments of his
sentence as may be requested
by this Office. It is
understood that, should this
Office determine either that
the defendant has not provided
substantial assistance in an
investigation or prosecution,
or that the defendant has
violated any provision of this
Agreement, such a
determination will release
this Office from any
obligation to file a motion
pursuant to Section 5K1.1 of
the Sentencing Guidelines, but
will not entitle the defendant
to withdraw his guilty plea
once it has been
entered. It is
understood that, should this
Office determine, subsequent
to the filing of a motion
pursuant to Section 5K1.1 of
the Sentencing Guidelines
and/or 18 U.S.C. $3553(e),
that the defendant has
violated any provision of this
Agreement, this Office shall
have the right to withdraw
such motion."
A sample TD
Bank letter to Gilbert Armenta
is here.
We'll have more on this.
On November 7 in
the case against accused
OneCoin money launderer Mark
Scott Konstantin Ignatov for
the third and last day took
the witness stand, in prison
blues with his neck and arm
tattoos, as a cooperating
witness.
Scott's
lawyer Arlo Devlin-Brown
zeroed in on Konstantin
Ignatov's guilty plea to bank
fraud, asking him to name
which FDIC insured bank he had
provided false information to.
Ignatov
could not name a US bank, only
United Bank of Dubai.
"No further
questions," Devlin-Brown told
Judge Ramos.
Inner City
Press has asked the US
Attorney's Office when it was
that Konstantin Ignatov pled
guilty, since he gave no
indication of such a plea in a
September 6 status conference
that Inner City Press covered,
and has asked if it was before
Judge Ramos, and if it was
sealed.
The
government's next witness was
the anti money laundering
expert Donald Semesky. Inner
City Press will continue to
cover the trial. November 7
thread here.
More on Patreon here.
On
November 6 Konstantin Ignatov
testified that the bodyguards
to took Ruja on her final
public trip told him she was
met by "Russian guys," and
that Ruja had told him that in
Russia she knew a rich and
powerful person. More on
Patreon, here.
November 6
came to an end in the trial
with Scott's lawyer Arlo
Devlin-Brown cross examining
Konstantin in detail about his
one and only in person meeting
with defendant Mark Scott,
when he visited OneCoin's
headquarters in Sophia,
Bulgaria. Inner City Press
will have more on this as the
trial continues on November 7.
Back on
November 4 before jury
selection, in oral arguments
Scott's lawyers asked Judge
Ramos to not allow into
evidence information and chats
found on a Samsung Galaxy
smart phone for which Mark
Scott paid but was used by his
wife, with a Russian keyboard.
Judge Ramos declined to
suppress it.
It also
emerged that still-missing
Ruja Ignatova rented space
underneath cooperator Gilbert
Armenta to listen in on him.
More on that and on jury
selection (which included
questions on multi level
marketing) is on Patreon, here.
On Monday,
October 28 in a two hour
pre-trial conference covered
by Inner City Press, Judge
Ramos said that the government
can show photos of Scott with
a yacht and cars that he
purchased.
The
government said the trial will
take two to three weeks.
The case
is US v.
Scott / Ignatov,
17-cr-630
(Ramos).
More
on Patreon, here.
***
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