From at least in or about 2020, through in or about May 2024, GUAN, while working as the Chief Financial Officer of a multinational media company headquartered in New York, New York (the “Media Company”), conspired with others to participate in a sprawling, transnational scheme to launder at least approximately $67 million of illegally obtained funds to bank accounts in the names of the Media Company and related entities (together, with the Media Company, the “Media Entities”). In furtherance of the money laundering conspiracy, GUAN managed, among other teams, the Media Company’s “Make Money Online” team (the “MMO Team”), which was located in a particular foreign office of the Media Company. Under GUAN’s management, members of the MMO Team and others used cryptocurrency to knowingly purchase tens of millions of dollars in crime proceeds, including proceeds of fraudulently obtained unemployment insurance benefits, that had been loaded onto tens of thousands of prepaid debit cards. The crime proceeds were generally purchased by the scheme participants, including members of the MMO Team and others working with them, using a particular cryptocurrency platform, at discounted rates of approximately 70 to 80 cents per dollar, and in exchange for cryptocurrency.
