Case 2:20-cv-05914 Document 1 Filed 07/01/20 Page 1 of 280 Page ID #:1 1 DEBORAH CONNOR, Chief Money Laundering and Asset Forfeiture Section (MLARS) 2 MARY BUTLER, Chief, International Unit WOO S. LEE, Deputy Chief, International Unit 3 BARBARA Y. LEVY, Trial Attorney JOSHUA L. SOHN, Trial Attorney 4 JONATHAN BAUM, Trial Attorney Criminal Division 5 United States Department of Justice 1400 New York Avenue, N.W., 10th Floor 6 Washington, D.C. 20530 Telephone: (202) 514-1263 7 Email:
[email protected] 8 Attorneys for Plaintiff 9 UNITED STATES OF AMERICA 10 UNITED STATES DISTRICT COURT 11 FOR THE CENTRAL DISTRICT OF CALIFORNIA 12 13 UNITED STATES OF AMERICA, No. CV 20-5914 14 Plaintiff, VERIFIED COMPLAINT FOR 15 v. FORFEITURE IN REM 16 ALL FUNDS AND ASSETS, [18 U.S.C. § 981(a)(1)(A) and (C)] 17 INCLUDING SECURITIES AND 18 INVESTMENTS, ON DEPOSIT IN [F.B.I.] FALCON PRIVATE BANK LIMITED 19 ACCOUNT NUMBERS ‘6001 AND 20 ‘6001.1001, 21 Defendants. 22 23 The United States of America (the “government”) brings this complaint against 24 the above-captioned assets and alleges as follows: 25 PERSONS AND ENTITIES 26 1. The plaintiff is the United States of America. 27 2. The defendants in this action are all funds and assets, including securities 28 and investments, on deposit in account numbers ‘6001 and ‘6001.1001 held by River Case 2:20-cv-05914 Document 1 Filed 07/01/20 Page 2 of 280 Page ID #:2 1 Dee International SA at Falcon Private Bank Limited (“Falcon Bank”) in Switzerland 2 more particularly described in Attachment A (“DEFENDANT ASSETS”).