1 DAVID L.

ANDERSON (CABN 149604) FILED

United States Attorney
2 Jun 23 2020

SUSANY. SOONG
3 CLERK, U.S. DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO
4

8 UNITED STATES DISTRICT COURT

9 NORTHERN DISTRICT OF CALIFORNIA

10 SAN FRANCISCO DIVISION

11

12 UNITED STATES OF AMERICA, ) CASE NO. CR 20-257 JD

)
13 Plaintiff, ) UNDER SEAL
)
14 v. ) VIOLATIONS:
) 18 U.S.C. §§ 1343, 1346 and 1349– Conspiracy to
15 WING LOK “WALTER” WONG, ) Commit Honest Services Wire Fraud; 18 U.S.C. §
) 1956(h) – Conspiracy to Commit Money Laundering;
16 Defendant. )
) 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c) –
17 ) Criminal Forfeiture
)
18 ) SAN FRANCISCO VENUE
)
19

20 INFORMATION
21 The United States Attorney charges:

22

23 COUNT ONE: (18 U.S.C. § 1349 – Conspiracy to Commit Honest Services Wire Fraud)
24 1. Beginning at an unknown date, but as early as in or about 2004 and continuing through in
25 or about January 2020, in the Northern District of California and elsewhere, the defendant,

26 WING LOK “WALTER” WONG

27 did knowingly and intentionally conspire with Mohammed NURU and others, including other public

28 officials for the City and County of San Francisco (the “City”), known and unknown to the United States

INFORMATION
 1 Attorney, to commit wire fraud, that is, having devised and intending to devise a material scheme and

2 artifice to defraud the City, and the citizens of San Francisco of their right to the honest and faithful

3 services of Mohammed NURU and other City officials through bribery, kickbacks, and the concealment

4 of material information, to transmit and cause to be transmitted by means of wire communication in

5 interstate commerce writings, signs, signals, pictures and sounds for the purpose of executing such

6 scheme and artifice, in violation of Title 18, United States Code, Sections 1343 and 1346. All in

7 violation of Title 18, United States Code, Section 1349.

9 COUNT TWO: (18 U.S.C. § 1956(h) – Conspiracy to Commit Money Laundering)

10 2. Beginning at an unknown date, but as early as in or about 2008 and continuing through in

11 or about January 2020, in the Northern District of California and elsewhere, the defendant,

12 WING LOK “WALTER” WONG

13 did knowingly combine, conspire, and agree with Mohammed NURU and with other persons known and

14 unknown to the United States Attorney, to knowingly conduct and attempt to conduct financial

15 transactions affecting interstate commerce and foreign commerce, which transactions involved the

16 proceeds of specified unlawful activity, that is, wire fraud, knowing that the transactions were designed

17 in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the

18 proceeds of specified unlawful activity, and that while conducting and attempting to conduct such

19 financial transactions, knew that the property involved in the financial transactions represented the

20 proceeds of some form of unlawful activity, in violation of Title 18, United States Code, Section

21 1956(a)(1)(B)(i). All in violation of Title 18, United States Code, Section 1956 (h).

22

23 FORFEITURE ALLEGATION: (18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c))

24 3. The allegations contained in this Information are re-alleged and incorporated by reference

25 for the purpose of alleging forfeiture pursuant to Title 18, United States Code, Section 981(a)(1)(C) and

26 Title 28, United States Code, Section 2461(c).

27 4. Upon conviction for any of the offenses set forth in this Information , the defendant,

28 “WING LOK” WALTER WONG,

INFORMATION 2
 1 shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C) and

2 Title 28, United States Code, Section 2461(c), all property, real or personal, constituting, or derived

3 from proceeds the defendant obtained directly and indirectly, as the result of those violations.

4 If any of the property described above, as a result of any act or omission of the defendant:

5 a. cannot be located upon exercise of due diligence;

6 b. has been transferred or sold to, or deposited with, a third party;

7 c. has been placed beyond the jurisdiction of the court;

8 d. has been substantially diminished in value; or

9 e. has been commingled with other property which cannot be divided without

10 difficulty,

11 the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 21,

12 United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c).

13 All pursuant to Title 18, United States Code, Section 981(a)(1)(C), Title 28, United States Code,

14 Section 2461(c), and Federal Rule of Criminal Procedure 32.2.

15

16 DATED:

17

18 DAVID L. ANDERSON
United States Attorney
19

20 _____________________________
SCOTT D. JOINER
21 S. WAQAR HASIB
Assistant United States Attorneys
22

23

24

25

26

27

28

INFORMATION 3
AO 257 (Rev. 6/78)

DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION - IN U.S. DISTRICT COURT

BY: COMPLAINT INFORMATION INDICTMENT Name of District Court, and/or Judge/Magistrate Location
SUPERSEDING NORTHERN DISTRICT OF CALIFORNIA
OFFENSE CHARGED
SAN FRANCISCO DIVISION
COUNT ONE: 18 U.S.C. §§ 1343, 1346 and 1349– Conspiracy Petty
to Commit Honest Services Wire Fraud;
Minor DEFENDANT - U.S
COUNT TWO: 18 U.S.C. § 1956(h) – Conspiracy to Commit
Misde- FILED
Money Laundering
meanor
 WING LOK “WALTER” WONG
Jun 23 2020
Felony
DISTRICT COURT NUMBER SUSANY. SOONG
PENALTY: PLEASE SEE PENALTY SHEET ATTACHMENT CLERK, U.S. DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
CR 20-257 JD SAN FRANCISCO

DEFENDANT
PROCEEDING IS NOT IN CUSTODY
Has not been arrested, pending outcome this proceeding.
Name of Complaintant Agency, or Person (& Title, if any) 1) If not detained give date any prior
Federal Bureau of Investigation
summons was served on above charges 
person is awaiting trial in another Federal or State Court, 2) Is a Fugitive
give name of court
3) Is on Bail or Release from (show District)

this person/proceeding is transferred from another district

per (circle one) FRCrp 20, 21, or 40. Show District
IS IN CUSTODY
4) On this charge
this is a reprosecution of
charges previously dismissed 5) On another conviction
which were dismissed on motion
of:
SHOW
DOCKET NO.
} Federal State

U.S. ATTORNEY DEFENSE

} 6) Awaiting trial on other charges
If answer to (6) is "Yes", show name of institution

this prosecution relates to a

Yes If "Yes"
pending case involving this same
defendant MAGISTRATE
Has detainer
been filed? No
} give date
filed
CASE NO.
prior proceedings or appearance(s)
before U.S. Magistrate regarding this
defendant were recorded under
} DATE OF
ARREST
 Month/Day/Year

Or... if Arresting Agency & Warrant were not

Name and Office of Person

Furnishing Information on this form David L. Anderson
DATE TRANSFERRED
TO U.S. CUSTODY
 Month/Day/Year

U.S. Attorney Other U.S. Agency

Name of Assistant U.S. This report amends AO 257 previously submitted

Attorney (if assigned) Scott D. Joiner
ADDITIONAL INFORMATION OR COMMENTS
PROCESS:
SUMMONS NO PROCESS* WARRANT Bail Amount:
If Summons, complete following:
Arraignment Initial Appearance * Where defendant previously apprehended on complaint, no new summons or
warrant needed, since Magistrate has scheduled arraignment
Defendant Address:

Date/Time: Before Judge:

Comments:
 PENALTY SHEET ATTACHMENT

Count One:

18 U.S.C. §§ 1343, 1346, 1349 – Conspiracy to Commit Honest Services Wire Fraud

Maximum Penalties: 20 years imprisonment

$250,000 fine or not more than the greater of twice the gross gain
or twice the gross loss
3 years supervised release
$100 special assessment
Forfeiture

Count Two:

18 U.S.C. § 1956(h) – Money Laundering Conspiracy

Maximum Penalties: 20 years imprisonment

$500,000 or twice the value of the monetary instrument or funds
involved in the transaction
3 years supervised release
$100 special assessment
Forfeiture