REGElVED

rN rHE uNrrED srArES DrsrRrcr couRr sEP I 2 2024

FOR THE DISTRICT OF COLUMBIA Clerk, U.S. District and
Bankruptcy Courts
Holding a Criminal Term
Grand Jury Sworn in on July 24,2024

UNITED STATES OF AMERICA : CRIMINAL NO.

v. VIOLATIONS:

DENIS POSTOVOY 18 U.S.C. $ 371

(Conspiracy to Defraud the United States)

Defendant. s0 u.s.c. s 4819

(Export Control Reform Act)

18 U.S.C. $ ss4
(Smuggling)

18 U.S.C. S 1956(h) (Conspiracy to

Commit Money Laundering)

FORFEITURE:
18 u.s.c. $ e81(a)(1)(A)
18 U.S.C. $ e8l(a)(l)(C) and
21 u.s.C. $ 8s3(p)

INDICTMENT

INTRODUCTION

The Grand Jury charges that, at times material to this Indictment:

1. Since at least February 2022, DENIS POSTOVOY ("POSTOVOY"), engaged in

the procurement and illicit export of U.S.-origin and other microelectronics that can be used in a

variety of civil and military applications, including unmanned aerial vehicles ("UAVs" or
oodrones").
Through a web of companies that he owns andlor operates in Russia, Hong Kong, and

elsewhere, POSTOVOY purchased microelectronics from U.S.-based and foreign-based

distributors and exported them to Russia without the required licenses.

2. In the course of exporting the microelectronics from the United States and other
places, POSTOVOY repeatedly concealed and misstated the true end users and end destinations

by submitting false information on documents, transshipped items that were ultimately destined

for Russia through intermediary destinations, including Hong Kong, Switzerland, and Estonia, and

received payments in U.S. dollars from foreign bank accounts.

3. After Russia's full-scale invasion of Ukraine on February 24,2022, and the

imposition of expanded restrictions on the export of microelectronics to Russia, POSTOVOY

continued to export controlled microelectronics to Russia despite knowing that such exports

required a license from the Department of Commerce, located in Washington, D.C., which neither

he nor his co-conspirators applied for or obtained.

THE DEFENDANT AND CO-CONSPIRATORS

4. DefendantDENIS POSTOVOYwas aRussian citizenresiding inthe United States

who was engaged in the business of procuring and exporting microelectronics.

5. POSTOVOY owned andior controlled the following companies in Hong Kong,

Russia, and the United States: WowCube HK Limited ("WowCube," located in Hong Kong); JST

Group Hong Kong (ooJST," located in Hong Kong); Jove HK Limited ("Jove," located in Hong

Kong); and Vector Group ("Vector," located in Russia).

6. Streloy E Commerce (a/Wa, Streloi Ekommerts) ("Streloy") was located in St.

Petersburg, Russia, and was sanctioned by the U.S. Government in December 2023. Streloy was

one of POSTOVOY's customers.

7. "Russian Company-l," whose identity is known to the Grand Jury, was located in

Zelenograd" Russia and was one of POSTOVOY's customers.

8. "Swiss Company-l," whose identity is knownto the Grand Jury, was owned and/or

controlled by Co-conspirator-l and was used by POSTOVOY to obtain sensitive microelectronics

from U.S. companies, including U.S. Company-l, for transshipment to Russia.

9. "Turkish Company-I," whose identity is known to the Grand Jury, was located in

Turkey and was used by POSTOVOY and Streloy to transship items to Russia.

10. "UC Company," whose identity is known to the Grand Jury, was a U.S.-based

company operated in an undercover capacity by a U.S. Government law enforcement agency.

POSTOVOY ordered an export-controlled microcontroller used in drone design and

manufacturing from the UC Company. This component was classified as Export Control

Classification Number ("ECCN") 34991 .a2 on the Commerce Control List ("CCL") and, after

February 24, 2022, required an export license to be shipped from the United States to Russia,

including through an intermediate destination such as Hong Kong.

11. "lJ.S. Company-I," whose identity is known to the Grand Jury, was a U.S.-based

distributor of semiconductors and electronic components. U.S. Company-l shipped an export-

controlled item used in drone design and manufacturing-an STM Microcontroller (manufactured

by STMicroelectronics, a Dutch company)-to both POSTOVOY and Co-conspirator-l. This

component was classified as ECCN 3A991.a on the CCL and, after February 24,2022, required

an export license to be shipped from the United States to Russia, including through an intermediate

destination such as Hong Kong.

12. "(J.S. Company-2," whose identity is known to the Grand Jury, was a U.S.-based

distributor of semiconductors and electronic components. U.S. Company-2 was scheduled to ship

an export-controlled item used in drone design and manufacturing-an XMOS Microcontroller

(manufactured by XMOS, a United Kingdom companyfto POSTOVOY. This component was

classified as ECCN 3A991.a2 onthe CCL and, after February 24,2022, required an export license

to be shipped I from the United States to Russia, including through an intermediate destination
such as Hong Kong.

13. "Co-conspirator-1," whose identity is known to the Grand Jury, was the Managing

Director of Swiss Company-1, which POSTOVOY used to transship items, directly and indirectly,

to Russia.

14. "Co-conspirator-2," whose identity is known to the Grand Jury, was a citizen of

Russia and was one of POSTOVOY's employees, who served in various roles, including as

Purchasing Manager for Jove, one of POSTOVOY's Hong Kong-based companies.

THE EXPORT CONTROL REFORM ACT

15. On August 13, 2018, the President signed into law the National Defense

Authorization Act of 2019, which included the Export Control Reform Act ("ECRA"). See 50

U.S.C. $ 4801 et seq. ECRA provided permanent statutory authority for the Export Administration

Regulations ("EAR"), Title 15, Code of Federal Regulations, Parts730-774.

16. ECRA provided that "the national security and foreign policy of the United States

require that the export, reexport, and in-country transfer of items, and specified activities of United

States persons, wherever located, be controlled." 50 U.S.C. $ 4811. To that end, ECRA granted

the President the authority to "(l) control the export, reexport, and in-country transfer of items

subject to the jurisdiction of the United States, whether by United States persons or foreign

persons; and (2) the activities of United States persons, wherever located, relating to" specific

categories of items and information. 50 U.S.C. $ 4812. ECRA granted to the Secretary of

Commerce the authority to establish the applicable regulatory framework. 50 U.S.C. $ 4813.

17. Through the EAR, the U.S. Department of Commerce's Bureau of Industry and

Security ("BIS") reviewed and controlled the export from the United States to foreign destinations

of certain items.'In particular, BIS placed restrictions on the export and reexport of items that it
determined could make a significant contribution to the military potential or nuclear proliferation

of other nations or that could be detrimental to the foreign policy or national security of the United

States. Under the EAR, such restrictions depended on several factors, including the technical

characteristics of the item, the destination country, the end user and the end use of the item.

18. The most sensitive items subject to EAR controls were identified on CCL set forth

in Title 15, Code of Federal Regulations, Part 774, Supplement Number 1. Items listed on the CCL

were categorized by ECCNs, each of which was subject to export control requirements depending

on destination, end use and end user of the item.

19. Since Russia's full-scale invasion of Ukraine on February 24,2022, BIS has

implemented a series of stringent export controls that restrict Russia's access to the technologies

and other items that it needs to sustain its attack on Ukraine. As of April 8, 2022, license

requirements for exports, reexports and transfers to or within Russia were expanded to cover all

items on the CCL. See 87 Fed. Reg. 12226 (Mar. 3,2022);87 Fed. Reg. 22130 (Apr. 14, 2022);

1s c.F.R. $ 746.8.

20. Under ECRA, it was a crime to willfully violate, attempt to violate, conspire to

violate or cause a violation of any regulation, order, license or authorization issued pursuant to the

statute, including the EAR. See 50 U.S.C. $ a819(a)(l).

COUNT ONE
Conspiracy to Commit an Offense Against the United States and to Defraud the United
States, in violation of Title 18, United States Code, Section 371

THE CONSPIRACY

21. Between at least in or about February 2022 and continuing to the present, the exact

dates being unknown to the Grand Jury, in the District of Columbia and elsewhere, the defendant,

DENIS POSTOVOY, and others, known and unknown to the Grand Jury, did knowingly combine,
conspire, confederate, and agree together and with each other, to commit offenses against the

United States and to defraud the United States, as follows:

a. to willfully export and cause the exportation of goods from the United States to

Russia without first having obtained the required licenses from the Department of

Commerce in violation of Title 50, United States Code, Section 4819(a), and Title

15, Code of Federal Regulations, Sections 736.2,746.8, and764.2;

b. to fraudulently and knowingly export and send and attempt to export and send from

the United States merchandise, articles, and objects contrary to laws and regulations

of the United States, and receive, conceal, buy, sell, and facilitate the transportation,

concealment, and sale of such merchandise, articles, and objects, prior to

exportation, knowing the same to be intended for exportation contrary to laws and

regulations of the United States, in violation of Title 18, United States Code,

Section 554;

c. to cause the transfer of funds from a place outside of the United States to a place in

the United States in promotion of a specified unlawful activity, that is smuggling,

in violation of Title 18, United States Code, Section 1956; and

d. to defraud the U.S. Govemment by interfering with and obstructing a laudll

government function, that is, the enforcement of laws and regulations controlling

the export of goods from the United States, by deceit, craft, trickery, and dishonest

means.

22. The allegations made in paragraphs I through 14 are hereby realleged and

incorporated by reference herein.

 GOALS OF THE CONSPIRACY

23. The goals of the conspiracy were:

a. to acquire, on behalf of entities in Russia, microelectronics and other sensitive

technologies that were manufactured and/or sold in the United States;

b. to export microelectronics and other sensitive technologies from the United States

directly and indirectly to Russia and to Russian end users, including through

intermediary destinations, such as Hong Kong;

c. to conceal through dishonest means the prohibited activities and transactions from

detection by the U.S. Government so as to avoid penalties and disruption of the

illegal activities;

d. to profit through these illegal activities; and

e. to undermine the efforts of U.S. Government agencies to enforce export laws and

regulations by evading the prohibitions and licensing requirements of ECRA and

the EAR.

MANNER AND MEANS OF THE CONSPIRACY

24. Defendant POSTOVOY and other co-conspirators, known and unknown to the

Grand Jury, used the following manner and means, among others, to accomplish the objects of the

conspiracy:

a. POSTOVOY and other co-conspirators, including Co-conspirator-1, Co-

conspirator-2, and individuals associated with Streloy, used email and other means

to communicate;

b. Vector, Co-conspirator-2, and individuals associated with Streloy, among others,

solicited quotes from and negotiated with POSTOVOY for the procurement of
 microelectronics and other sensitive technologies;

POSTOVOY purchased items or caused items to be purchased from companies in

the United States to fuIfiIl orders from Russian customers, including by providing

false information to the U.S. companies;

d. POSTOVOY and other co-conspirators, including Co-conspirator-1, Co-

conspirator-2, and individuals associated with POSTOVOY's other companies,

arranged for shipment of the microelectronics and other sensitive technologies from

the United States to transshipment points in Hong Kong, Switzerland, and

elsewhere, to conceal the true end users and end destinations in Russia;

e. POSTOVOY and individuals associated with POSTOVOY's companies

transferred funds for the purchase and shipment of the goods through bank accounts

in Hong Kong and elsewhere to bank accounts in the United States maintained by

POSTOVOY, U.S. Company-l, or other U.S. suppliers of microelectronics and

other sensitive technologies; and

POSTOVOY and other co-conspirators caused the microelectronics and other

sensitive technologies to be exported from the United States to individuals and

entities in Russia without obtaining the required licenses from the U.S. Department

of Commerce.

FAILURE TO OBTAIN A LICENSE

25. During the relevant time period, the below items were identified on the CCL,

classified by BIS under the corresponding ECCNs, and controlled for anti-terrorism reasons. As

of February 24,2022, an export license was required from the Department of Commerce to export

or reexport each of these items to Russia.

 Exnorted Item ECCN
STMicroelectronics STM32G49lCCU6 ECCN 3A99I.a
Microcontrollers
xMos xEF216-512-TQt28-r204 ECCN 34991.a2
Microcontroller
Infineon SAK-XC2785X-l04F80LR ECCN 34991.a2
Microcontrollers

No person, including Defendant POSTOVOY, sought or obtained the required licenses from the

Department of Commerce, which is located in Washington, D.C., in order to lawfully conduct the

commercial transactions and related shipments and wire transfers set forth in this Indictment.

OVERT ACTS IN FURTHERANCE OF THE CONSPIRACY

26. In furtherance of the conspiracy and to achieve the objects thereof, the defendant

POSTOVOY and co-conspirators committed and caused to be committed the following overt acts,

among others, in the District of Columbia and elsewhere:

TRANSACTION WITH U.S. COMPANY-I

27 . On or about March 8,2021, POSTOVOY-acting on behalf of his Russia-based

company, Vector-signed a contract with Jove, one of his companies located in Hong Kong. The

contract, identified as Contract No. 03/21-01 (the "Contract"), govemed the purchase of items

procured by Jove that would be exported to Vector in Russia. Under the contract, Jove was

identified as the "Supplier" and Vector was identified as the "Buyer." Pursuant to the Contract,

Jove, as the supplier/seller, would sell and Vector, as the buyer, would purchase specific

components and quantities that would be detailed in subsequently executed addenda to the
Contract. For each shipment, Jove was required under the Contract to include a commercial

invoice, with reference to the Contract and the terms of delivery, and apacking slip.

28. On or about May 6, 2022, Jove and Vector executed "specification 16 to the

Contract No. 03/21-01," which identified the components to be shipped as 1,000 pieces of a
"microcontroller" with part number STM32G491CCU6 (the "STM Microcontroller") and 1,200

pieces of "Electronic module Eazy ECG USB" (the"Eazy USB").

29. On or about May 23,2022, Jove placed two orders with U.S. Company-l for 40

pieces of the STM Microcontroller.

30. On or about July 13, 2022, Jove paid U.S. Company-1 for these components via a

wire transfer originating from Jove's account at "Multinational Financial Institution-1," whose

identity is known to the Grand Jury, in Hong Kong. The wire, totaling $15,237,was deposited into

U.S. Company-l's account in the United States. U.S. Company-l's business records further show

that, while the "bill to" parly for the order was Jove, the recipient of the components was JST, a

separate company based in Hong Kong that was owned by POSTOVOY.

31. The actions of POSTOVOY and his co-conspirators caused U.S. Company-l to

export 40 pieces of the STM Microcontroller from the United States to JST in Hong Kong on or

about May 23, 2022 and on or about May 24, 2022. The true ultimate consignee of these

components was Vector, located in Russia, afact not disclosed to U.S. Company-1.

32. Beginning on or about }1.ay 20, 2022, POSTOVOY also arranged for several

hundred pieces of the STM Microcontroller to be purchased from U.S. Company-l by Co-

conspirator-l using Swiss Company-l. Over the ensuing weeks, POSTOVOY caused Co-

conspirator-l to procure over 1,000 pieces of the STM Microcontroller from U.S. Company-l,

take delivery of these components in Switzerland and then, at POSTOVOY's direction, export the

items ultimately to Russia via Hong Kong or Europe.

33. On or about June 8, 2022, Jove sent a commercial invoice to Vector for 1,000

pieces of the STM Microcontroller and 1,200 pieces of the Eary USB. The commercial invoice

identified the Contract and a previously issued proforma invoice, and it also listed POSTOVOy

10
as the point of contact for Vector. As required by the Contract, the invoice included the "terms of

transportation." The total price of the items was listed as $246,840 and was denominated in U.S.

Dollars.

34. Also on or about June 8, 2022,Jove submitted apacking list. Provision of apacking

list was required under the Contract. The packing list identified Jove as the exporter/shipper and

Vector as the importer/consignee. It also stated that the contents of the shipment included 1,000

pieces of the STM Microcontroller and referenced Proforma Invoice 16 of May 6,2022.

35. On or about June 8, 2022, Jove submitted customs documents to the Russian

Customs Clearance Department. These documents, translated from Russian, stated that the import

to Russia contained 1,000 pieces of the STM Microcontroller and 1,200 pieces of the Eazy USB.

The documents identified the seller as Jove and the o'Declarant" as vector.

36. On or about June 28, 2022, the actions of POSTOVOY and his co-conspirators

caused the following financial transactions to occur: U.S. Financial Instifution-l, located in the

United States and acting as the intermediary bank for an international wire transfer, received

$315,499 from Rosbank in Moscow, Russia. The originator of the transfer was Vektor Grupp (i.e.,

Vector) and the beneficiary was the account for Jove at Multinational Financial Institution-l in

Hong Kong. The "remittance information" accompanying the wire transfer was "payment by

invoicesNo.0l5 andNo.016" "forgoods." This amountmatches the sum of the invoices for

Specification 16 and a separate Specification to the Contract. U.S. Financial Institution-l then

forwarded the $315,499 to the correspondent account of Multinational Financial Institution-l

(Hong Kong) at Multinational Financial Institution-l (New york).

TRANSACTION WITH THE U.S. COMPANY-2

37. In or about Nil2022, POSTOVOY, acting on behalf of Jove, signed a contract

11
(Contract No. 04122-03) with Russian Company-l to procure microelectronics for Russian

Company-I.

38. On or about March 21,2023, POSTOVOY, acting on behalf of Jove, and Russian

Company-l executed "Supplementary Agreement #2 to the Contract No.04122-03" ("Supplement

#2") dated April 20, 2022.

39. On or about that same day, Co-conspirator-2 sent an email to an email address

associated with Russian Company-l. Attached to the email was "Specification 004 to the Contract

No. 04122-03" and a proforma invoice that referenced Contract No. 04122-03. The specification

and invoice were each for 1,080 pieces of a "microcontroller" with part number XEF2L6-512-

TQ128-I20A (the "XMOS Microcontroller"). The specification and invoice were signed by

POSTOVOY, and the specification identified Jove as the seller and Russian Company-l as the

buyer.

40. On or about January 19, 2023, between the execution of Contract No. 04122-03

and Supplement#Z, Co-conspirator-2-acting as the representative of Jove---ordered 1,080 pieces

of the XMOS Microcontroller with part numberXEF2L6-512-TQ128-120A from U.S. Company-

2. According to a purchase order on U.S. Comparry-2letterhead, the buyer of the items was

identified as Co-conspirator2llove, and the item was listed on the purchase order as subject to the

EAR under "ECCN 3A991A2." The total on the purchase order was listed as $20,859. The true

ultimate end-user of these components was Russian Company-l , a fact not disclosed to U.S.

Company-2.

41. On or about March 24,2023, Jove, using its Hong Kong-based financial account,

wired $20,860 into an account held by an Asia-based affiliate of U.S. Company-2 at Multinational

Financial Institution-l (Hong Kong).

t2
 TRANSACTION WITH THE UC COMPANY

42. On or about September 28,2022, Co-conspirator-2 sent an email to an employee

of Streloy. The email included an attached invoice issued by Jove for 60,000 pieces of a

"microcontroller" with partial part number SAK-XC2785X-104F80LR (the "Infineon

Microcontroller"). The invoice listed the "bill to" party as Turkish Company-l and the "ship to"

party as "to be confirmed."

43. On or about November 19,2022, POSTOVOY sent an email to the UC Company

requesting a purchase order for, among other components, 60,000 pieces of the Infineon

Microcontroller. On or about January 20,2023, the UC Company issued a proforma invoice to

POSTOVOY for the requested components, including the Infineon Microcontroller. The invoice,

which totaled $865,000 ($420,000 for the Infineon Microcontrollers and the balance for other

components in the order), included a statement regarding restrictions and prohibitions under U.S.

export controls.

44. POSTOVOY instructed the UC Company to list on the BIS Form 711 ("Statement

by Ultimate Consignee and Purchaser") a Hong Kong-based company as the Ultimate Consignee

for this order, despite Jove's issuance of the invoice to Streloy for the same part and quantity. The

identification of the Hong Kong-based company as the Ultimate Consignee was false, which

POSTOVOY knew.

45. Beginning on or about January 27,2023, POSTOVOY made seven wire payments

totaling $620,000 to the UC Company's account at U.S. Financial Institution-2,located in the

United States. The payments came from WowCube's Hong Kong-based account at U.S. Financial

Institution-l and were in partial fulfillment of the proforma invoice sent to POSTOVOY on

January 20,2023.

13
 46. On or about May 9, 2023, POSTOVOY caused the UC Company to ship apackage

purporting to contain the Infineon Microcontroller and other parts ordered from the UC Company.

(Conspiracy to Commit an Offense Against the United States and to Defraud the United
States, in violation of Title 18, United States Code, Section 371.)

COUNTS TWO throueh FOUR

(Export Control Reform Act, in violation of Title 50, United States Code, Section 4819)
47. The factual allegations in paragraphs 1 through 14 and 21 through 46 of this

Indictment are hereby realleged and incorporated by reference herein.

48. On or about the dates listed for each count, in the District of Columbia and

elsewhere, DENIS POSTOVOY and others known and unknown to the Grand Jury, did knowingly

and willfully violate Title 50, United States Code, Section 4819, by exporting, attempting to

export, and causing the export and attempted export of goods, as listed below, to Russia, without

first having obtained authorization or a license from the U.S. Department of Commerce.

Count Approx. Date U.S. Vendor Description of ltem(s)

ofExnort
2 May 23 - June U.S. Company-l STMicroelectronics
7,2022 STM32G491CCU6
Microcontrollers
J May 21,2023 U.S. Company-2 xMos xEF2t6-512-
TQ128-r20A
Microcontrollers
4 May 9,2023 UC Company Infineon SAK-XC2785X-
104F80LR
Microcontrollers

(Export Control Reform Act, in violation of Title 50, United States Code, Section 4819)
COUNTS FIVE throueh SIX
(Smuggling Goods from the United States)

49. The factual allegations in paragraphs I through 14 and 2l through 48 of this

Indictment are hereby realleged and incorporated by reference herein.

50. On or about the dates listed for each count, in the District of Columbia and

t4
elsewhere, the defendant, DENIS POSTOVOY, fraudulently and knowingly attempted to export

and send from the United States the merchandise, articles, and objects as identified in each count,

contrary to the laws and regulations of the United States, to wit, Title 50, United States Code,

Section 4819 and the EAR, and fraudulently and knowingly received, concealed, bought, sold, and

facilitated the transportation, concealment, and sale of such merchandise, articles, and objects,

prior to exportation, knowing the same to be intended for export contrary to such laws and

regulations of the United States.

Count Approx. Date U.S. Vendor Description of ltem(s)

ofExnort
5 May 23 - June U.S. Company-l STMicroelectronics
7,2022 STM32G49ICCU6
Microcontrollers
6 May 9,2023 UC Company Infineon SAK-XC2785X-
104F80LR
Microcontrollers

(Smuggling goods from the United States, in violation of Title 18, United States Code, Section
ss4.)

COUNT SEVEN
(Conspiracy to Commit Money Laundering)

51. The factual allegations in paragraphs 1 through 14 and2l through 50 of this

Indictment are hereby realleged and incorporated by reference herein.

52. Beginning on or about the dates specified below, in the District of Columbia and

elsewhere, the defendant, DENIS POSTOVOY, and others known and unknown to the Grand Jury,

within the venue of the United States District Court for the District of Columbia, did knowingly,

combine, conspire, confederate and agree with each other, and others known and unknown to the

Grand Jury, to violate Title 18, United States Code, Section 1956(a)(2)(A), by transporting,

transmitting, and transferring monetary instruments and funds to and through a place in the United

States from and through a place outside the United States, and from and through a place in the

t5
United States to and through a place outside the United States, to wit, Russia and Hong Kong, with

the intent to promote the carrying on of specified unlawful activity, that is, violations of 18 U.S.C.

Section 554.

GOALS OF CONSPIRACY

53. The goals of the conspiracy were:

a. To promote the conspirators' illegal business transactions;

b. To conceal and disguise the nature, the location, the source, the ownership, and the

control of the proceeds of illegal business transactions; and

c. To illegally enrich the conspirators.

MANNER AND MEANS OF CONSPIRACY

54. At all relevant times during the conspiracy, Vector maintained bank accounts in

Russia at Rosbank.

55. At all relevant times during the conspiracy, POSTOVOY and his companies,

including Jove and Wowcube, maintained bank accounts at the Hong Kong branch of U.S.

Financial Institution-l.

56. At all relevant times during the conspiracy, the UC Company maintained bank

accounts in the United States at U.S. Financial Institution-2.

57. Vector's, Wowcube's, and Jove's bank accounts in Russia and Hong Kong were

utilized on at least five separate occasions to wire transfer funds into or through the United States

in exchange for goods smuggled from the United States.

58. On or about June 28, 2022, U.S. Financial Institution-l, located in the United States

and acting as the intermediary bank for an international wire transfer, received $315,499 from

Rosbank in Moscow, Russia. The originator of the transfer was Vektor Grupp (i.e.,Yector) and

t6
the beneficiary was the account for Jove at Multinational Financial Institution-l (Hong Kong). The

"remittance information" accompanying the wire transfer was "payment by invoices No. 015 and

No. 016" "for goods." This amount matches the sum of the invoices for Specification 16, which

concerned the STM Microcontrollers, and a separate Specification to the Contract. U.S. Financial

Institution-l forwarded the $315,499 to the correspondent account of Multinational Financial

Institution-l (Hong Kong) at Multinational Financial Institution-1 (New York).

59. Beginning on or about January 27,2023, POSTOVOY made seven wire payments

totaling $620,000 to the UC Company's account at U.S. Financial Institution-2,located in the

United States. The payments came from WowCube's Hong Kong-based account at U.S. Financial

Institution-l and were in partial fulfillment of the proforma invoice sent to POSTOVOY on

January 20,2023, which concerned the Infineon Microcontroller.

(Laundering of Monetary Instruments, in violation of Title 18, United States Code, Section
1es6(h).)

FORFEITURE NOTICE
60. The allegations contained in Counts One through Seven of this Indictment are

hereby realleged and incorporated by reference for the purpose of alleging forfeiture pursuant to

Title 28, United States Code, Section zail@),

61. Pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United

States Code, Section 2461(c), upon conviction of violations of ECRA, Title 50, United States

Code, Section 4819; and Smuggling, Title 18, United States Code, Section 554, Defendant

POSTOVOY shall forfeit to the United States of America any property, real or personal, which

constitutes or is derived from proceeds traceable to said violation(s). The United States will also

seek a forfeiture money judgment for a sum of money equal to the value of any property, real or

personal, which constitutes, or is derived from proceeds traceable to this offense.

t7
 62. The allegations contained in Counts One through Seven of this Indictment are

hereby re-alleged and incorporated by reference for the purpose ofalleging forfeitures pursuant to

Title 18, United States Code, Section 982(aX1). Pursuant to Title 18, United States Code, Section

982(a)(l), upon conviction of an offense in violation of Title 18, United States Code, Section 1956,

Defendant POSTOVOY shall forfeit to the United States of America any property, real or personal,

involved in such offbnse, and any property traceable to such property. The United States will also

seek a forfeiture money judgment for a sum of money equal to the value of any property, real or

personal, which constitutes, or is derived from proceeds traceable to this offense.

63. If any of the property described above, as a result of any act or omission of the

defendant:

a. cannot be located upon the exercise ofdue diligence;

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

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

d. has been substantially diminished in value; or

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

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

21, United States Code, Section 853(p) as incorporated by Title 28, United States Code, Section

2a6t@).

A TRUE BILL

FOREPERSON

fu,*h/S^'",,,-kt
Nnomey of the United States in
and for the District of Columbia

18