Case 1:16-cr-00026-RJA-MJR Document 14 Filed 04/13/16 Page 1 of 6

IN THE DISTRICT COURT OF THE UNITED STATES

for the Western District of New York
____________________
NOVEMBER 2014 GRAND JURY
(Impaneled 11/07/2014)

THE UNITED STATES OF AMERICA

-vs-

SUPERSEDING INDICTMENT
16-CR-26-A
Violations:
Title 18, United States Code, Sections
1956(a)(1)(A)(i), 1956(h), 1957(a) and 2;
Title 21, United States Code, Sections
846 and 963
(5 Counts and 2 Forfeiture Allegations)

ZHE WANG
(Counts 1-5),
KEVIN SZURA
(Counts 1-5), and
ADAM BRZOZOWSKI
(Counts 1-2)
COUNT 1

(Conspiracy to Distribute Controlled Substances)

The Grand Jury Charges That:
Beginning in or before March 2015, the exact date being unknown to the Grand
Jury, and continuing until on or about March 7, 2016, in the Western District of New York,
and elsewhere, the defendants, ZHE WANG, KEVIN SZURA, and ADAM
BRZOZOWSKI, did knowingly, willfully, and unlawfully combine, conspire, and agree
together and with others, known and unknown to the Grand Jury, to commit the following
offenses, that is, to possess with the intent to distribute, and to distribute, Schedule I and II
controlled substances, and alprazolam, a Schedule IV controlled substance, in violation of
Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(C), and 841(b)(2).
All in violation of Title 21, United States Code, Section 846.

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COUNT 2
(Conspiracy to Import Alprazolam)
The Grand Jury Further Charges That:
Beginning in or before March 2015, the exact date being unknown to the Grand
Jury, and continuing until on or about March 7, 2016, in the Western District of New York,
and elsewhere, the defendants, ZHE WANG, KEVIN SZURA, and ADAM
BRZOZOWSKI, did knowingly, willfully, and unlawfully combine, conspire, and agree
together and with others, known and unknown to the Grand Jury, to commit the following
offense, that is, to import into the United States quantities of alprazolam, a Schedule IV
controlled substance, in violation of Title 21, United States Code, Sections 952(b), 960(a)(1),
960(b)(6), and 841(b)(2).
All in violation of Title 21, United States Code, Section 963.

COUNT 3
(Money Laundering Conspiracy)
The Grand Jury Further Charges That:
Beginning in or before March 2015, the exact date being unknown to the Grand
Jury, and continuing until on or about March 7, 2016, in the Western District of New York,
and elsewhere, the defendants, ZHE WANG and KEVIN SZURA, did knowingly,
willfully, and unlawfully combine, conspire, and agree together and with others, known and
unknown to the Grand Jury, to commit the following offenses, that is:
a.

to knowingly conduct financial transactions affecting interstate and foreign

commerce, that is, the purchase, with United States currency, of bitcoins over and through
2

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the use of the Internet, which involved the proceeds of specified unlawful activity, that is,
the unlawful importation and distribution of controlled substances, and conspiracy to do so,
in violation of Title 21, United States Code, Sections 841(a)(1), 846, 952(b), 960(a)(1), and
963, with the intent to promote the carrying on of such specified unlawful activity, and
while knowing that the property involved in the financial transactions, that is, the United
States currency, represented the proceeds of some form of unlawful activity, in violation of
Title 18, United States Code, Section 1956(a)(1)(A)(i); and
b.

to knowingly engage in a monetary transaction within the United States, that

is, the transfer and exchange of United States currency for bitcoins over and through the use
of the Internet, affecting interstate and foreign commerce, in criminally derived property of
a value greater than $10,000, such property, that is, the United States currency, having been
derived from specified unlawful activity, that is, the unlawful importation and distribution
of controlled substances, and conspiracy to do so, in violation of Title 21, United States
Code, Sections 841(a)(1), 846, 952(b), 960(a)(1), and 963; all in violation of Title 18, United
States Code, Section 1957(a).
All in violation of Title 18, United States Code, Section 1956(h).

COUNT 4
(Money Laundering)
The Grand Jury Further Charges That:
On or about February 29, 2016, in the Western District of New York, the
defendants, ZHE WANG and KEVIN SZURA, did knowingly conduct, and attempt to
conduct, a financial transaction affecting interstate and foreign commerce, that is, the
3

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purchase, with United States currency, of bitcoins over and through the use of the Internet,
which involved the proceeds of specified unlawful activity, that is, the unlawful importation
and distribution of controlled substances, and conspiracy to do so, in violation of Title 21,
United States Code, Sections 841(a)(1), 846, 952(b), 960(a)(1), and 963, with the intent to
promote the carrying on of such specified unlawful activity, and while knowing that the
property involved in the financial transaction, that is, the United States currency,
represented the proceeds of some form of unlawful activity.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(A)(i) and 2.

COUNT 5
(Monetary Transaction in Criminally Derived Property)
The Grand Jury Further Charges That:
On or about February 29, 2016, in the Western District of New York, the
defendants, ZHE WANG and KEVIN SZURA, did knowingly engage, and attempt to
engage, in a monetary transaction within the United States, that is, the transfer and
exchange of United States currency for bitcoins over and through the use of the Internet,
affecting interstate and foreign commerce, in criminally derived property of a value greater
than $10,000, such property, that is, the United States currency, having been derived from
specified unlawful activity, that is, the unlawful importation and distribution of controlled
substances, and conspiracy to do so, in violation of Title 21, United States Code, Sections
841(a)(1), 846, 952(b), 960(a)(1), and 963.
All in violation of Title 18, United States Code, Sections 1957(a) and 2.

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FIRST FORFEITURE ALLEGATION

(Drug Proceeds)
The Grand Jury Alleges That:
Upon conviction of either offense alleged in Counts 1 and 2 of the Superseding
Indictment, the defendants, ZHE WANG, KEVIN SZURA, and ADAM BRZOZOWSKI,
shall forfeit to the United States of America all of their interest in any and all property, real
or personal, constituting or derived from any proceeds that they obtained, directly or
indirectly, as the result of such violation, including, but not limited to, the following
property:
CURRENCY:
a.

The sum of eleven thousand eight hundred and thirty-four dollars

($11,834.00) in United States currency seized by federal law
enforcement officers from the defendant Zhe Wang on March 7, 2016;

b.

The sum of ten thousand eight hundred eighty-two dollars

($10,882.00) in United States currency seized by federal law
enforcement officers from the defendant Kevin Szura on March 7,
2016; and

c.

The sum of eight thousand four hundred and eighty dollars ($8,480.00)
in United States currency given to federal law enforcement officers by
the defendants in exchange for bitcoins on March 7, 2016.

MONETARY JUDGMENT:
a.

The sum of sixty-five thousand eight hundred and sixty dollars

($65,860.00) in United States currency, the value of bitcoins purchased
and received by the defendants, and if not readily available, to be
secured by a money judgment in said amount.

All pursuant to Title 21, United States Code, Sections 853(a)(1) and 853(a)(2).

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SECOND FORFEITURE ALLEGATION

(Money Laundering)
The Grand Jury Further Alleges That:
Upon conviction of any of the offenses alleged in Counts 3 through 5 of the
Superseding Indictment, the defendants, ZHE WANG and KEVIN SZURA, shall forfeit to
the United States all property involved in the offenses including, but not limited to, the
following property:
CURRENCY:
a.

The sum of eight thousand four hundred and eighty dollars ($8,480.00)
in United States currency given to federal law enforcement officers by
the defendants in exchange for bitcoins on March 7, 2016.

MONETARY JUDGMENT:
a.

The sum of sixty-five thousand eight hundred and sixty dollars

($65,860.00) in United States currency, the value of bitcoins purchased
and received by the defendants, and if not readily available, to be
secured by a money judgment in said amount.

All pursuant to Title 18, United States Code, Section 982(a)(1).

DATED: Buffalo, New York, April 13, 2016.
WILLIAM J. HOCHUL, JR.
United States Attorney
BY:

S/WEI XIANG
Assistant United States Attorney
United States Attorneys Office
Western District of New York
138 Delaware Avenue
Buffalo, New York 14202
716/843-5806
Wei.Xiang@usdoj.gov

A TRUE BILL:
S/FOREPERSON