United States District Court Western District of Washington at Seattle, United States of America v. Roman Seleznev, Superseding Indictment, March 16, 2011. Unclassified.
National Security Archive
The 2011 superseding indictment of Roman Seleznev reveals how U.S. prosecutors first fused traditional bank‑fraud law with cyber‑intrusion tactics to takedown a global card‑theft network.
Source: United States District Court Western District of Washington at Seattle, United States of America v. Roman Seleznev, Superseding Indictment, March 16, 2011. Unclassified. Date: Mar 16, 2011 Archive: Krebs on Security Collection: Cyber Vault: IRS Employees and Electronic Filing Fraud Sep 20, 2017
Editorial Analysis
Original analysis by the DriftSeas editorial desk. The complete primary-source document, transcribed from the National Security Archive scan, appears in full below.
A cyber‑crime indictment at the crossroads of law and digital warfare
The superseding indictment filed on March 16, 2011, against Roman Seleznev emerged from a Seattle grand jury convened after a wave of high‑profile credit‑card “carding” operations that threatened the stability of regional banks. By late 2009 a cluster of retail point‑of‑sale breaches in Washington state had produced unusually large charge‑back losses for institutions such as Boeing Employees’ Credit Union and Capital One. Federal prosecutors, led by the U.S. Attorney’s Office in Seattle, responded by assembling a grand jury to untangle a sprawling, transnational infrastructure of malware servers, rented hosting space, and online pseudonyms. The indictment is the legal crystallization of that effort, naming Seleznev—known online as “TRACK2,” “Bulba,” and a host of other handles—as the alleged architect of a scheme that combined traditional bank fraud statutes with the emerging language of cyber‑intrusion.
The indictment’s place in the broader fight against organized cyber‑theft
Seleznev’s case sits at a pivotal moment in U.S. cyber‑policy. The late 2000s saw the Department of Justice expand the use of the 1994 Computer Fraud and Abuse Act (CFAA) to target not just hackers but the commercial ecosystems that monetized stolen data. The indictment’s reliance on 18 U.S.C. § 1343 (wire fraud) and § 1344 (bank fraud) illustrates the DOJ’s strategy of framing digital theft as a financial crime, thereby invoking harsher penalties and enabling asset‑forfeiture tools traditionally reserved for racketeering. Moreover, the document reveals an early awareness of the “service‑provider” problem: the servers used to host malware were located in Ukraine, Russia, and even Virginia, highlighting the jurisdictional challenges that continue to vex law‑enforcement today.
What the indictment tells us about the actors and their methods
Beyond the litany of aliases, the indictment paints Seleznev as a technically sophisticated operator who managed a global “carding” supply chain. It details his use of “port scanning” to locate vulnerable point‑of‑sale systems, the rental of overseas servers to host malware such as “shmak” and “kameo,” and the operation of card‑selling forums like “bulba.cc.” The specificity—down to IP addresses and domain names—signals that investigators had infiltrated the network, likely through undercover online personas and cooperation with private cybersecurity firms. The mention of a server in McLean, Virginia, used to compile stolen track data, suggests a deliberate effort to route illicit proceeds through U.S. infrastructure, perhaps to evade detection by foreign law‑enforcement partners. The indictment’s language also hints at a hierarchy: Seleznev is portrayed as the mastermind, yet the text acknowledges “others unknown to the Grand Jury,” indicating a broader, possibly organized crime ring that remains partially concealed.
Legacy and why the document still matters
The Seleznev indictment set a precedent for how U.S. prosecutors would later tackle high‑profile cybercriminals, from the 2013 “Operation Ghost Click” bust to the 2020 indictment of Russian‑linked ransomware groups. By anchoring digital theft in traditional bank‑fraud statutes, the case broadened the prosecutorial toolbox and signaled to the cyber underground that anonymity alone would not shield them from federal reach. The case also foreshadowed the growing reliance on public‑private partnerships; the detailed technical evidence likely stemmed from collaboration with security researchers and financial institutions that shared logs and malware samples.
In the years since, Seleznev was convicted and sentenced to 27 years in prison—a sentence that remains one of the longest for a cyber‑theft case. The indictment’s meticulous cataloguing of servers, malware, and online handles continues to serve as a reference point for investigators mapping modern carding operations. Its legacy endures in policy debates over the scope of the CFAA, the ethics of “hacking back,” and the international cooperation required to dismantle cyber‑crime ecosystems that effortlessly cross borders.
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1 Presented to the Court by the foreman of the 2 Grand Jury in open Court, in the presence of the Grand Jury and FILED in the U.S. DISTRICT COURT at Seattle, Washington. Judge Richard A. Jones 3 [MARCH 16 2011] 4 WILLIAM Mc COOL, Clerk 5 By [illegible] Deputy 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 UNITED STATES OF AMERICA, ) NO. CR11-070RAJ 11 Plaintiff, ) SUPERSEDING 12 v. ) INDICTMENT 13 ROMAN SELEZNEV, ) (SEALED) 14 aka TRACK2, ) aka ROMAN IVANOV, ) 15 aka RUBEN SAMVELICH, ) aka nCuX, ) 16 aka Bulba, ) aka bandysli64, ) 17 aka smaus, ) aka Zagreb, ) 18 aka shmak. ) 19 Defendant. ) 20 The Grand Jury charges that: 21 COUNTS 1 - 5 22 (Bank Fraud) 23 A. The Offense 24 1. Beginning at a time unknown, but no later than October 2, 2009, and 25 continuing through on or about February 22, 2011, within the Western District of 26 Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN 27 IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, 28
INDICTMENT/Seleznev, Roman. - 1 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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aka Zagreb, aka shmak (hereinafter Roman Seleznev), and others unknown to the Grand Jury, knowingly and willfully devised and executed, and aided and abetted a scheme and artifice to defraud various financial institutions, including, but not limited, to Boeing Employees’ Credit Union (“BECU”), Chase Bank, Capital One, Citibank, and Keybank (“the banks”), financial institutions as defined by Title 18, United States Code, Section 20, and to obtain moneys, funds, and credits under the custody and control of the banks by means of material false and fraudulent pretenses, representations and promises, as further described below.
- The object of the scheme and artifice to defraud was to “hack” into the computers of retail businesses within the Western District of Washington, and elsewhere; to install malicious computer code onto those hacked computers that would effectively steal the credit card numbers of the victim businesses’ customers; to market and sell the stolen credit card numbers, on criminally inspired websites, for the purpose and with the intent that the stolen credit card numbers would then in turn be used for fraudulent transactions across the United States, and in foreign countries; and, by way of the scheme, to obtain illicit proceeds, funded by and derived primarily from the banks (located in the Western District of Washington, and elsewhere), that had originally issued the stolen credit card numbers. By way of this series of criminal actions, the defendants intended to and did generate and receive millions of dollars in illicit profits, that they then converted to their own personal benefit and use.
B. Manner and Means of the Scheme and Artifice to Defraud
ROMAN SELEZNEV has used “nics” or online nicknames in his dealings and his communications with others regarding and promoting the theft and sale of stolen credit card numbers that include: “TRACK2,” “nCuX,” “Bulba,” “bandysli64,” “smaus,” “Zagreb,” and “shmak.”
It was part of the scheme and artifice to defraud that ROMAN SELEZNEV, and others unknown to the Grand Jury, created a criminally inspired, Internet-based
INDICTMENT/Seleznev, Roman. - 2
UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 infrastructure to facilitate the theft, and then the sale, over the Internet, of credit card
2 account numbers that had been issued by banks, including BECU.
3 5. It was further part of the scheme and artifice to defraud that, as part of that
4 criminal Internet-based infrastructure, ROMAN SELEZNEV, and others unknown to the
5 Grand Jury, rented, configured, and controlled server computers in countries outside of
6 the United States, including the Ukraine and Russia, that contained malware, or malicious
7 computer code, which servers would provide downloads of that malware, onto other
8 computers, when the requesting computers were commanded to made such a request.
9 The server that hosted the malware was "named" "shmak.fvds.ru," aka
10 "smaus.fvds.ru" aka "188.120.225.66" and all of the malware was located, on the server,
11 at shmak.fvds.ru/
INDICTMENT/Seleznev, Roman. - 3 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 by retail businesses, and that would be vulnerable to criminal hacks for the purpose of 2 stealing credit card numbers. 3 9. It was further part of the scheme and artifice to defraud that ROMAN 4 SELEZNEV, and others unknown to the Grand Jury, used those automated techniques to 5 identify credit card processing computers at the Broadway Grill restaurant, and at other 6 businesses in the Western District of Washington as well as throughout the United States, 7 as target computers for their criminal scheme. 8 10. It was further part of the scheme and artifice to defraud that once ROMAN 9 SELEZNEV, and others unknown to the Grand Jury, identified credit card processing 10 computers that were vulnerable to criminal hacks, they issued commands to the target 11 computers to connect, over the Internet, to the servers that they had previously rented and 12 configured and that they controlled, in the Ukraine and Russia, and to download malware 13 from those servers, so that it would be installed on the victim target computers. 14 Specifically, once ROMAN SELEZNEV, and others unknown to the Grand Jury 15 had remote control of a victim computer, they would launch a web browser on the victim 16 computer. They would then type the address for the server hosting the malware 17 ("shmak.fvds.ru,") followed by the name of the piece of malware they wished to have 18 downloaded (for example, "shmak.fvds.ru/kameo.exe"). The piece of malware specified 19 could vary, as between the many different pieces of malware that were being hosted on 20 the Ukraine/Russian server. Once this web address was typed into the address bar of the 21 victim computer, the victim computer would download this piece of malware from the 22 Ukraine/Russian server. 23 Once the malware was installed on the victim computer, ROMAN SELEZNEV, 24 and others unknown to the Grand Jury, could disconnect from the victim computer. The 25 malware that had been downloaded was preconfigured to upload credit card data that 26 subsequently passed through the victim computer, to the server that had been designated 27 by ROMAN SELEZNEV, and others unknown to the Grand Jury, for that purpose. 28
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UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 In some cases ROMAN SELEZNEV, and others unknown to the Grand Jury, also 2 installed a piece of software that would enable them to easily remotely reconnect to the 3 victim servers again, at a later date. 4 11. It was further part of the scheme and artifice to defraud that the malware 5 that ROMAN SELEZNEV, and others unknown to the Grand Jury caused to be installed 6 on the targeted victim computers included software that monitored network activity 7 within the business' internal computer network. The businesses that were targeted 8 typically had several computers running, including a few "point of sale" terminals, and/or 9 other computers that employees used to process orders, and to swipe customer credit 10 cards when purchases were made. These computers were in turn connected to a 11 computer, commonly referred to as the "the back of the house computer," or the 12 "manager's computer," that would receive all of the credit card track data that had been 13 gathered from the point of sale terminals; encrypt that data; and transmit it to the 14 merchant card processor for approval. 15 The malware that ROMAN SELEZNEV, and others unknown to the Grand Jury 16 caused to be downloaded to the victim business' computers monitored the traffic within 17 the business' computer network and intercepted the communications between the point of 18 sale terminals and the back of the house computer. The malware would extract and copy 19 the data that included credit card track data and, every five minutes, compile the stolen 20 credit card track data and transmit and upload it to a server identified by a specified IP 21 address. That server had been previously rented and configured and was controlled by 22 ROMAN SELEZNEV, and others unknown to the Grand Jury, for that purpose, and could 23 be located in a variety of geographic locations, including in Russia, the Ukraine, or, for a 24 time, in McLean, Virginia. 25 12. It was further part of the scheme and artifice to defraud that one of the 26 business computer networks that was found vulnerable, and was hacked by ROMAN 27 SELEZNEV and others unknown to the Grand Jury, was that of the Broadway Grill 28 restaurant, in Seattle, WA. In the case of the Broadway Grill, in particular, every credit
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1 card number that had been swiped at the restaurant between December 1, 2009, and 2 October 22, 2010, (over 32,000 unique credit card numbers) had been saved to a text file 3 that was stored on the business' back of the house computer. ROMAN SELEZNEV, and 4 others unknown to the Grand Jury, commanded the computer they hacked at the 5 Broadway Grill restaurant to steal, transmit, and upload that complete text file, containing 6 all of those unique credit card numbers, to computer servers specified by ROMAN 7 SELEZNEV, and others unknown to the Grand Jury, that had previously been rented and 8 configured and that were under their control, for that purpose. 9 ROMAN SELEZNEV, and others unknown to the Grand Jury, also caused and 10 commanded the DTC2.exe malware to be installed on the manager's credit card 11 processing computer at the Broadway Grill, in the manner described above, which 12 malware then continued to steal any additional credit card track data, including credit card 13 numbers, run after October 22, 2010. That data, as well, was transmitted from the 14 infected Broadway Grill computer over the Internet, to computer servers specified, 15 configured, and controlled by ROMAN SELEZNEV, and others unknown to the Grand 16 Jury, for that purpose. The theft of credit card track data from Broadway Grill continued 17 thereafter until the intrusion and theft were discovered on October 27, 2010. 18 13. It was further part of the scheme and artifice to defraud that, using the same 19 techniques described above that were used to hack into, install malware, and steal credit 20 card track data from the Broadway Grill restaurant in Seattle, WA, ROMAN 21 SELEZNEV, and others unknown to the Grand Jury, hacked into, installed malware, and 22 stole credit card tract data from a number of other small retail businesses in the Western 23 District of Washington including, but not limited to: Grand Central Baking Company 24 restaurant, in Seattle, WA; four Mad Pizza restaurants (three Seattle, WA, locations and a 25 location in Tukwila, WA); Village Pizza, in Anacortes, WA, and Casa Mia Italian 26 restaurant, in Yelm, WA. 27 14. It was further part of the scheme and artifice to defraud that, using the same 28 techniques described above that were used to hack into, install malware, and steal credit
INDICTMENT/Seleznev, Roman. - 6
UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 card track data from the Broadway Grill restaurant and other businesses in the Western 2 District of Washington, ROMAN SELEZNEV, and others unknown to the Grand Jury 3 likewise hacked into, installed malware, and stole credit card tract data from hundreds of 4 retail businesses in other locations throughout the United States, including, but not limited 5 to: Schlotzsky's Deli, in Coeur d'Alene, Idaho; Active Networks, in Frostburg, Maryland; 6 Days Jewelry, in Waterville, Maine; Latitude Bar and Grill, in New York, New York; 7 Grand Canyon Theatre, in Tusayan, Arizona; the Phoenix Zoo, in Phoenix, Arizona; 8 Mary's Pizza Shack, in Sonoma, California; and City News Stand (a convenience store), 9 at multiple store locations in Evanston, and Chicago, Illinois. 10 15. It was further part of the scheme and artifice to defraud that after credit card 11 track data was transmitted from hacked businesses, and then compiled on the servers that 12 ROMAN SELEZNEV, and others unknown to the Grand Jury had previously rented, 13 configured, and controlled for that purpose, ROMAN SELEZNEV, and others unknown 14 to the Grand Jury, harvested the data, and extracted and segregated from it credit card 15 account numbers, Bank Identification Numbers ("BIN numbers,") and any other data 16 possible, including names of the account holders or PIN numbers, that would enhance the 17 value of the data for sale to those who wished to use it for criminal fraudulent purposes. 18 16. It was further part of the scheme and artifice to defraud that after ROMAN 19 SELEZNEV, and others unknown to the Grand Jury, had stolen, harvested, and 20 segregated the data that was valuable for sale to their would-be criminal customers, they 21 then posted and marketed that data for sale on carding forum websites, including those 22 named, "bulba.cc" and "Track2.name," which websites they had established on computer 23 servers that they had rented, configured, and which they controlled, for this purpose. The 24 stolen credit card numbers that they marketed and sold on these carding forum websites 25 included credit card numbers that had been issued by BECU, and by other banks in the 26 Western District of Washington and throughout the United States. 27 17. It was further part of the scheme and artifice to defraud that when ROMAN 28 SELEZNEV, and others unknown to the Grand Jury advertised and sold stolen credit card
INDICTMENT/Seleznev, Roman. - 7 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 numbers, BIN numbers, and related stolen data for sale on their carding forum websites, 2 they priced that data at varying levels, depending on its relative worth for use in 3 fraudulent transactions. For example, credit card numbers with a “95%” guarantee for 4 validity were priced between $20 and $30 per credit card track. This comprised the 5 majority of the cards listed for sale. There were also credit card numbers listed at lower, 6 “sale” prices. These were listed with a guarantee of validity of around “65%,” and were 7 listed for sale at around $7 per track. 8 18. It was further part of the scheme and artifice to defraud that ROMAN 9 SELEZNEV, and others unknown to the Grand Jury would seek to attract and entice 10 customers to their carding forum websites by advertising “fresh dumps” of stolen data, 11 which included, for example, an advertisement on November 24, 2010, as follows: 12 UPDATE OF 38,000 USA (TRACK1+2) AND 5.000 USD 13 TRACK2 ONLYTOTALLY MADE!!! 14 90% VALID! BIG BASE, NEW60 - TRACK1+TRACK2, 15 NEW61 - TRACK2 ONLY 16 And through an advertisement on December 23, 2010, as follows: 17 UPDATE 17,000 FRESH DUMPS TOTALY MADE! VALID 18 VERY HIGH 95%!! 19 75% TRACK1 + TRACK2 AND OTHER TRACK2 ONLY!!! 20 Base - NEW65 21 Warning - today checker not work at all. Sorry for that . 22 Merry XMAS!:). THAT IS THE LAST UPDATE IN THIS YEAR. Hurry up to 23 fund account 24 19. It was further part of the scheme and artifice to defraud that ROMAN 25 SELEZNEV, and others unknown to the Grand Jury, sought to enhance the value and to 26 spur sales of the stolen credit card data they marketed, for fraudulent use, by offering a 27 “checker” service through the carding forum websites, which, for a fee, would enable 28 customers to obtain instant validation information for the stolen credit card numbers, and
INDICTMENT/Seleznev, Roman. - 8 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 through which they also offered to “replace” numbers that were found to be invalid 2 through the checking service with an equal number of other stolen credit card numbers. 3 20. It was further part of the scheme and artifice to defraud that ROMAN 4 SELEZNEV, and others unknown to the Grand Jury, who controlled and operated the 5 bulba.cc and Track2.name carding forum websites, would only accept payment for the 6 stolen data that they sold through a limited number of payment services, including 7 webmoney services such as “Liberty Reserve,” because those services hinder efforts to 8 trace the proceeds of the transactions and effectively conceal the identity of both the 9 payers and the recipients of the proceeds of the same. 10 21. It was further part of the scheme and artifice to defraud that, in order to 11 expand and maximize their customer base for stolen credit card numbers, ROMAN 12 SELEZNEV, and others unknown to the Grand Jury, advertised the carding forums that 13 they owned and controlled on other well known carding forum websites, such as 14 “crdsu.su” and “carder.biz.” 15 22. It was further part of the scheme and artifice to defraud that, in order to 16 quash competition from other criminal carders, ROMAN SELEZNEV, and others 17 unknown to the Grand Jury, assumed total control and a monopoly over stolen credit card 18 sales made on the previously established and preeminent carder forum website named 19 “crdsu.su,” in or around May of 2010. 20 23. It was further part of the scheme and artifice to defraud that ROMAN 21 SELEZNEV, and others unknown to the Grand Jury, stole over 200,000 credit card 22 numbers, and sold over 140,000 stolen credit card numbers through their carding forum 23 websites, bulba.cc and Track2.name, during the period from November 15, 2010, to 24 February 22, 2011. 25 24. It was further part of the scheme and artifice to defraud that ROMAN 26 SELEZNEV, and others unknown to the Grand Jury, generated illicit profits totaling at 27 least $2,000,000.00 from the sale of stolen credit card information on the bulba.cc and 28 track2.name websites during the period from November 15, 2010, to February 22, 2011.
INDICTMENT/Seleznev, Roman. - 9 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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- It was further part of the scheme and artifice to defraud that the stolen credit card numbers sold by ROMAN SELEZNEV, and others unknown to the Grand Jury, have been used to commit fraudulent transactions throughout the United States, including specifically in the States of Texas and New York, and throughout the world.
- It was further part of the scheme and artifice to defraud that credit card numbers, in particular, that were stolen from the Broadway Grill by ROMAN SELEZNEV, and others unknown to the Grand Jury, which credit card numbers had been issued by BECU, were used in fraudulent transactions after their sale on the bulba.cc and track2.name websites for fraudulent transactions that have caused losses to BECU of at least $79,317.00; and that credit card numbers stolen from Broadway Grill that were issued by other banks, and sold on the bulba.cc and Track2.name websites, have caused losses to the other banks that issued those cards in the amount of at least $1,763,140.56. C. Execution of the Scheme and Artifice to Defraud
- On or about the below-listed dates, within the Western District of Washington and elsewhere, for the purpose of executing and attempting to execute this scheme and artifice to defraud, ROMAN SELEZNEV, and others unknown to the Grand Jury, did knowingly and willfully steal the credit card account numbers specified below, that had been issued by BECU, which account numbers subsequently were used in fraudulent transactions, causing a loss to BECU in the amounts specified below:
| Count | Date CC # Stolen | CC Acct. Number Issued by BECU | BECU Fraud Loss on Acct. No. Due to Fraudulent Transactions |
|---|---|---|---|
| 1 | 10/22/2010 | ************5719 | $1199.59 |
| 2 | 10/22/2010 | ************6316 | $650.14 |
| 3 | 10/22/2010 | ************7089 | $636.86 |
| 4 | 10/22/2010 | ************0016 | $317.98 |
| 5 | 10/22/2010 | ************0717 | $394.60 |
All in violation of Title 18, United States Code, Sections 1344 and 2.
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UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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COUNT 6
(Intentional Damage to a Protected Computer)
Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if fully set forth herein.
On or about October 22, 2010, within the Western District of Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, aka shmak, knowingly caused the transmission of a program, information, code, and command, and as a result of that conduct, intentionally caused and attempted to cause damage, without authorization, to a protected computer, to wit, by causing the installation of malware on a credit card processing computer belonging to and located at the Broadway Grill restaurant, in Seattle, WA, and by such conduct caused loss to one or more persons during a one year period aggregating at least $5,000 in value.
All in violation of Title 18, United States Code, Sections 1030(a)(5)(A), and 1030(c)(4)(B)(i), and 2.
COUNT 7
(Intentional Damage to a Protected Computer)
Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if fully set forth herein.
On or about October 2, 2009, within the Western District of Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, aka shmak, knowingly caused the transmission of a program, information, code, and command, and as a result of that conduct, intentionally caused and attempted to cause damage, without authorization, to a protected computer, to wit, by causing the installation of malware on a credit card processing computer belonging to and located at the Grand
INDICTMENT/Seleznev, Roman. - 11
UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 Central Baking Company restaurant, in Seattle, WA, and by such conduct caused loss to 2 one or more persons during a one year period aggregating at least $5,000 in value. 3 All in violation of Title 18, United States Code, Sections 1030(a)(5)(A), and 4 1030(c)(4)(B)(i), and 2. 5 6 COUNT 8 7 (Intentional Damage to a Protected Computer) 8 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 9 fully set forth herein. 10 2. On or about August 28, 2010, within the Western District of Washington 11 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 12 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 13 aka shmak, knowingly caused the transmission of a program, information, code, and 14 command, and as a result of that conduct, intentionally caused and attempted to cause 15 damage, without authorization, to a protected computer, to wit, by causing the installation 16 of malware on a credit card processing computer belonging to and located at the Mad 17 Pizza restaurant, in Tukwila, WA, and by such conduct caused loss to one or more 18 persons during a one year period aggregating at least $5,000 in value. 19 All in violation of Title 18, United States Code, Sections 1030(a)(5)(A), and 20 1030(c)(4)(B)(i), and 2. 21 22 COUNT 9 23 (Intentional Damage to a Protected Computer) 24 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 25 fully set forth herein. 26 2. On or about November 2, 2010, within the Western District of Washington 27 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 28 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb,
INDICTMENT/Seleznev, Roman. - 12 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 aka shmak, knowingly caused the transmission of a program, information, code, and 2 command, and as a result of that conduct, intentionally caused and attempted to cause 3 damage, without authorization, to a protected computer, to wit, by causing the installation 4 of malware on a credit card processing computer belonging to and located at the Mad 5 Pizza restaurant, 1263 Thomas Street, Seattle, WA, and by such conduct caused loss to 6 one or more persons during a one year period aggregating at least $5,000 in value. 7 All in violation of Title 18, United States Code, Sections 1030(a)(5)(A), and 8 1030(c)(4)(B)(i), and 2. 9 10 COUNT 10 11 (Intentional Damage to a Protected Computer) 12 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 13 fully set forth herein. 14 2. On our about October 22, 2010, within the Western District of Washington 15 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 16 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 17 aka shmak, knowingly caused the transmission of a program, information, code, and 18 command, and as a result of that conduct, intentionally caused and attempted to cause 19 damage, without authorization, to a protected computer, to wit, by causing the installation 20 of malware on a credit card processing computer belonging to and located at the Mad 21 Pizza restaurant, 1321 Madison St., Seattle, WA, and by such conduct caused loss to one 22 or more persons during a one year period aggregating at least $5,000 in value. 23 All in violation of Title 18, United States Code, Sections 1030(a)(5)(A), and 24 1030(c)(4)(B)(i), and 2. 25 26 27 28
INDICTMENT/Seleznev, Roman. - 13 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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COUNT 11 (Intentional Damage to a Protected Computer)
Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if fully set forth herein.
On our about August 26, 2010, within the Western District of Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, aka shmak, knowingly caused the transmission of a program, information, code, and command, and as a result of that conduct, intentionally caused and attempted to cause damage, without authorization, to a protected computer, to wit, by causing the installation of malware on a credit card processing computer belonging to and located at the Mad Pizza restaurant, 4021 E. Madison St., Seattle, WA, and by such conduct caused loss to one or more persons during a one year period aggregating at least $5,000 in value.
All in violation of Title 18, United States Code, Sections 1030(a)(5)(A), and 1030(c)(4)(B)(i), and 2.
COUNT 12 (Intentional Damage to a Protected Computer)
Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if fully set forth herein.
On our about September 13, 2010, within the Western District of Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, aka shmak, knowingly caused the transmission of a program, information, code, and command, and as a result of that conduct, intentionally caused and attempted to cause damage, without authorization, to a protected computer, to wit, by causing the installation of malware on a credit card processing computer belonging to and located at
INDICTMENT/Seleznev, Roman. - 14
UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 the Village Pizza restaurant, in Anacortes, WA, and by such conduct caused loss to one or 2 more persons during a one year period aggregating at least $5,000 in value. 3 All in violation of Title 18, United States Code, Sections 1030(a)(5)(A), and 4 1030(c)(4)(B)(i), and 2. 5 6 COUNT 13 7 (Intentional Damage to a Protected Computer) 8 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 9 fully set forth herein. 10 2. On our about August 9, 2010, within the Western District of Washington 11 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 12 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 13 aka shmak, knowingly caused the transmission of a program, information, code, and 14 command, and as a result of that conduct, intentionally caused and attempted to cause 15 damage, without authorization, to a protected computer, to wit, by causing the installation 16 of malware on a credit card processing computer belonging to and located at the Casa 17 Mia Italian Pizzeria restaurant, in Yelm, WA, and by such conduct caused loss to one or 18 more persons during a one year period aggregating at least $5,000 in value. 19 All in violation of Title 18, United States Code, Sections 1030(a)(5)(A), and 20 1030(c)(4)(B)(i), and 2. 21 22 COUNT 14 23 (Obtaining Information From a Protected Computer) 24 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 25 fully set forth herein. 26 2. Beginning on a date uncertain, but on or about October 22, 2010, and 27 continuing until on or about October 27, 2010, within the Western District of Washington 28 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka
INDICTMENT/Seleznev, Roman. - 15 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 2 aka shmak, intentionally accessed a computer without authorization, and thereby obtained 3 information from a protected computer, to wit, they intentionally accessed a credit card 4 processing computer belonging to and located at the Broadway Grill restaurant, in Seattle, 5 WA, and obtained therefrom credit card track data that included credit card account 6 numbers issued by Boeing Employees Credit Union or other financial institutions as 7 defined by Title 18, United States Code, Section 20; and that they committed such offense 8 in furtherance of a criminal and tortious act in violation of the Constitution and laws of 9 the United States, specifically, bank fraud, in violation of Title 18, United States Code, 10 Section 1344. 11 All in violation of Title 18, United States Code, Sections 1030(a)(2) and 12 1030(c)(2)(B)(ii), and 2. 13 14 COUNT 15 15 (Obtaining Information From a Protected Computer) 16 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 17 fully set forth herein. 18 2. Beginning on a date uncertain, but on or about October 2, 2009, and 19 continuing until on or about December 1, 2010, within the Western District of 20 Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN 21 IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, 22 aka Zagreb, aka shmak, intentionally accessed a computer without authorization, and 23 thereby obtained information from a protected computer, to wit, they intentionally 24 accessed a credit card processing computer belonging to and located at the Grand Central 25 Baking Company restaurant, in Seattle, WA, and obtained therefrom credit card track data 26 that included credit card account numbers issued by Boeing Employees Credit Union or 27 other financial institutions as defined by Title 18, United States Code, Section 20; and 28 that they committed such offense in furtherance of a criminal and tortious act in violation
INDICTMENT/Seleznev, Roman. - 16 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 of the Constitution and laws of the United States, specifically, bank fraud, in violation of
2 Title 18, United States Code, Section 1344.
3 All in violation of Title 18, United States Code, Sections 1030(a)(2) and
4 1030(c)(2)(B)(ii) and 2.
5
6 **COUNT 16**
7 **(Obtaining Information From a Protected Computer)**
8 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if
9 fully set forth herein.
10 2. Beginning on a date uncertain, but on or about August 28, 2010, and
11 continuing until on or about February 1, 2011, within the Western District of Washington
12 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka
13 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb,
14 aka shmak, intentionally accessed a computer without authorization, and thereby obtained
15 information from a protected computer, to wit, they intentionally accessed a credit card
16 processing computer belonging to and located at the Mad Pizza restaurant, in Tukwila,
17 WA, and obtained therefrom credit card track data that included credit card account
18 numbers issued by Boeing Employees Credit Union or other financial institutions as
19 defined by Title 18, United States Code, Section 20; and that they committed such offense
20 in furtherance of a criminal and tortious act in violation of the Constitution and laws of
21 the United States, specifically, bank fraud, in violation of Title 18, United States Code,
22 Section 1344.
23 All in violation of Title 18, United States Code, Sections 1030(a)(2) and
24 1030(c)(2)(B)(ii) and 2.
25
26
27
28
INDICTMENT/Seleznev, Roman. - 17
UNITED STATES ATTORNEY
700 Stewart Street, Suite 5220
Seattle, Washington 98101-1271
(206) 553-7970
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1 COUNT 17 2 (Obtaining Information From a Protected Computer) 3 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 4 fully set forth herein. 5 2. Beginning on a date uncertain, but on or about November 2, 2010, and 6 continuing until on or about February 1, 2011, within the Western District of Washington 7 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 8 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 9 aka shmak, intentionally accessed a computer without authorization, and thereby obtained 10 information from a protected computer, to wit, they intentionally accessed a credit card 11 processing computer belonging to and located at the Mad Pizza restaurant, 1263 Thomas 12 St., Seattle, WA, and obtained therefrom credit card track data that included credit card 13 account numbers issued by Boeing Employees Credit Union or other financial institutions 14 as defined by Title 18, United States Code, Section 20; and that they committed such 15 offense in furtherance of a criminal and tortious act in violation of the Constitution and 16 laws of the United States, specifically, bank fraud, in violation of Title 18, United States 17 Code, Section 1344. 18 All in violation of Title 18, United States Code, Sections 1030(a)(2) and 19 1030(c)(2)(B)(ii) and 2. 20 21 COUNT 18 22 (Obtaining Information From a Protected Computer) 23 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 24 fully set forth herein. 25 2. Beginning on a date uncertain, but on or about October 22, 2010, and 26 continuing until on or about February 15, 2011, within the Western District of 27 Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN 28 IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus,
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1 aka Zagreb, aka shmak, intentionally accessed a computer without authorization, and 2 thereby obtained information from a protected computer, to wit, they intentionally 3 accessed a credit card processing computer belonging to and located at the Mad Pizza 4 restaurant, 1321 Madison St., Seattle, WA, and obtained therefrom credit card track data 5 that included credit card account numbers issued by Boeing Employees Credit Union or 6 other financial institutions as defined by Title 18, United States Code, Section 20; and 7 that they committed such offense in furtherance of a criminal and tortious act in violation 8 of the Constitution and laws of the United States, specifically, bank fraud, in violation of 9 Title 18, United States Code, Section 1344. 10 All in violation of Title 18, United States Code, Sections 1030(a)(2) and 11 1030(c)(2)(B)(ii) and 2. 12 13 COUNT 19 14 (Obtaining Information From a Protected Computer) 15 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 16 fully set forth herein. 17 2. Beginning on a date uncertain, but on or about August 26, 2010, and 18 continuing until on or about February 15, 2011, within the Western District of 19 Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN 20 IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, 21 aka Zagreb, aka shmak, intentionally accessed a computer without authorization, and 22 thereby obtained information from a protected computer, to wit, they intentionally 23 accessed a credit card processing computer belonging to and located at the Mad Pizza 24 restaurant, 4021 E. Madison St., Seattle, WA, and obtained therefrom credit card track 25 data that included credit card account numbers issued by Boeing Employees Credit Union 26 or other financial institutions as defined by Title 18, United States Code, Section 20; and 27 that they committed such offense in furtherance of a criminal and tortious act in violation 28
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UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 of the Constitution and laws of the United States, specifically, bank fraud, in violation of 2 Title 18, United States Code, Section 1344. 3 All in violation of Title 18, United States Code, Sections 1030(a)(2) and 4 1030(c)(2)(B)(ii) and 2. 5 6 COUNT 20 7 (Obtaining Information From a Protected Computer) 8 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 9 fully set forth herein. 10 2. Beginning on a date uncertain, but on or about September 25, 2010, and 11 continuing until on or about February 8, 2011, within the Western District of Washington 12 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 13 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 14 aka shmak, intentionally accessed a computer without authorization, and thereby obtained 15 information from a protected computer, to wit, they intentionally accessed a credit card 16 processing computer belonging to and located at the Village Pizza restaurant, Anacortes, 17 WA, and obtained therefrom credit card track data that included credit card account 18 numbers issued by Boeing Employees Credit Union or other financial institutions as 19 defined by Title 18, United States Code, Section 20; and that they committed such offense 20 in furtherance of a criminal and tortious act in violation of the Constitution and laws of 21 the United States, specifically, bank fraud, in violation of Title 18, United States Code, 22 Section 1344. 23 All in violation of Title 18, United States Code, Sections 1030(a)(2) and 24 1030(c)(2)(B)(ii) and 2. 25 26 27 28
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UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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COUNT 21 (Obtaining Information From a Protected Computer)
Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if fully set forth herein.
Beginning on a date uncertain, but on or about August 9, 2010, and continuing until on or about February 23, 2011, within the Western District of Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, aka shmak, intentionally accessed a computer without authorization, and thereby obtained information from a protected computer, to wit, they intentionally accessed a credit card processing computer belonging to and located at the Casa Mia Italian Pizzeria restaurant, Yelm, WA, and obtained therefrom credit card track data that included credit card account numbers issued by Boeing Employees Credit Union or other financial institutions as defined by Title 18, United States Code, Section 20; and that they committed such offense in furtherance of a criminal and tortious act in violation of the Constitution and laws of the United States, specifically, bank fraud, in violation of Title 18, United States Code, Section 1344.
All in violation of Title 18, United States Code, Sections 1030(a)(2) and 1030(c)(2)(B)(ii) and 2.
COUNT 22 (Possession of Fifteen or More Unauthorized Access Devices)
Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if fully set forth herein.
On or about January 20, 2011, within the Western District of Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, aka shmak, knowingly and with intent to defraud, possessed fifteen or more unauthorized
INDICTMENT/Seleznev, Roman. - 21
UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 access devices, that is, credit card account numbers that belonged to individuals who were 2 customers of businesses located within the Western District of Washington, which credit 3 card account numbers ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 4 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 5 aka shmak, stole from businesses, including the Broadway Grill, the Grand Central 6 Baking Company, several Mad Pizza restaurants, Village Pizza, and Casa Mia Italian 7 Pizzeria, located in the Western District of Washington, said possession affecting 8 interstate and foreign commerce, in that the unauthorized access devices were possessed 9 in order to market and sell them to others, for the intended purpose of making fraudulent 10 purchases in multiple states within the United States, and foreign countries. 11 All in violation of Title 18, United States Code, Sections 1029(a)(3) and 12 1029(c)(1)(A)(i), and 2. 13 14 COUNT 23 15 (Trafficking in Unauthorized Access Devices) 16 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 17 fully set forth herein. 18 2. From on or about November 15, 2010, to on or about November 16, 2010, 19 within the Western District of Washington and elsewhere, ROMAN SELEZNEV, aka 20 TRACK2, aka ROMAN IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, 21 aka bandysli64, aka smaus, aka Zagreb, aka shmak, knowingly and with intent to defraud, 22 trafficked in credit card track data, including credit card account numbers for credit card 23 accounts that were established through and issued by the Boeing Employees Credit 24 Union, in the Western District of Washington, and by such conduct, from on or about 25 November 15, 2010, and ending on or about November 16, 2010, obtained profits 26 aggregating approximately $83,490.00, said trafficking affecting interstate and foreign 27 commerce, in that the credit card account numbers that were so trafficked were in turn 28
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UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 used to make fraudulent purchases in multiple states within the United States, and foreign 2 countries. 3 All in violation of Title 18, United States Code, Sections 1029(a)(2) and 4 1029(c)(1)(A)(i), and 2. 5 6 COUNT 24 7 (Trafficking in Unauthorized Access Devices) 8 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 9 fully set forth herein. 10 2. From on or about January 31, 2011, to on or about February 1, 2011, within 11 the Western District of Washington and elsewhere, ROMAN SELEZNEV, aka TRACK2, 12 aka ROMAN IVANOV, aka RUBEN SAMVELICH, aka nCuX, aka Bulba, aka 13 bandysli64, aka smaus, aka Zagreb, aka shmak, knowingly and with intent to defraud, 14 trafficked in credit card track data, including credit card account numbers for credit card 15 accounts that were established through and issued by the Boeing Employees Credit 16 Union, in the Western District of Washington, and by such conduct, from on or about 17 January 31, 2011, and ending on or about February 1, 2011, obtained profits aggregating 18 approximately $30,716.00, said trafficking affecting interstate and foreign commerce, in 19 that the credit card account numbers that were so trafficked were in turn used to make 20 fraudulent purchases in multiple states within the United States, and foreign countries. 21 All in violation of Title 18, United States Code, Sections 1029(a)(2) and 22 1029(c)(1)(A)(i), and 2. 23 24 25 26 27 28
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1 COUNT 25 2 (Aggravated Identity Theft) 3 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 4 fully set forth herein. 5 2. On or about October 22, 2010, within the Western District of Washington 6 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 7 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 8 aka shmak, knowingly transferred, possessed and used, without lawful authority, a means 9 of identification of another person, to wit, the personally identifiable credit card number 10 of --**-5719, belonging to D.K., of Seattle, WA, within the Western District 11 of Washington, during and in relation to a felony listed in Title 18, United States Code, 12 Section 1028A(c), to wit, Bank Fraud, in violation of Title 18, United States Code, 13 Section 1344. 14 All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. 15 16 COUNT 26 17 (Aggravated Identity Theft) 18 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 19 fully set forth herein. 20 2. On or about October 22, 2010, within the Western District of Washington 21 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 22 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 23 aka shmak, knowingly transferred, possessed and used, without lawful authority, a means 24 of identification of another person, to wit, the personally identifiable credit card number 25 of --**-7089, belonging to N.S., of Seattle, WA, within the Western District 26 of Washington, during and in relation to a felony listed in Title 18, United States Code, 27 28
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UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 Section 1028A(c), to wit, Bank Fraud, in violation of Title 18, United States Code, 2 Section 1344. 3 All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. 4 5 COUNT 27 6 (Aggravated Identity Theft) 7 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 8 fully set forth herein. 9 2. On or about October 22, 2010, within the Western District of Washington 10 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 11 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 12 aka shmak, knowingly transferred, possessed and used, without lawful authority, a means 13 of identification of another person, to wit, the personally identifiable credit card number 14 of --****-0016, belonging to T.A., of Seattle, WA, within the Western District 15 of Washington, during and in relation to a felony listed in Title 18, United States Code, 16 Section 1028A(c), to wit, Bank Fraud, in violation of Title 18, United States Code, 17 Section 1344. 18 All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. 19 20 COUNT 28 21 (Aggravated Identity Theft) 22 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 23 fully set forth herein. 24 2. On or about October 22, 2010, within the Western District of Washington 25 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 26 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 27 aka shmak, knowingly transferred, possessed and used, without lawful authority, a means 28 of identification of another person, to wit, the personally identifiable credit card number
INDICTMENT/Seleznev, Roman. - 25 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
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1 of --**-0717, belonging to J.H., of Seattle, WA, within the Western District 2 of Washington, during and in relation to a felony listed in Title 18, United States Code, 3 Section 1028A(c), to wit, Bank Fraud, in violation of Title 18, United States Code, 4 Section 1344. 5 All in violation of Title 18, United States Code, Sections 1028A(a)(1), and 2. 6 7 COUNT 29 8 (Aggravated Identity Theft) 9 1. Paragraphs 1 through 26 of Counts 1-5 are realleged and incorporated as if 10 fully set forth herein. 11 2. On or about October 22, 2010, within the Western District of Washington 12 and elsewhere, ROMAN SELEZNEV, aka TRACK2, aka ROMAN IVANOV, aka 13 RUBEN SAMVELICH, aka nCuX, aka Bulba, aka bandysli64, aka smaus, aka Zagreb, 14 aka shmak, knowingly transferred, possessed and used, without lawful authority, a means 15 of identification of another person, to wit, the personally identifiable credit card number 16 of --**-6316, belonging to L.S., of Seattle, WA, within the Western District 17 of Washington, during and in relation to a felony listed in Title 18, United States Code, 18 ////////////////////////////// 19 ////////////////////////////// 20 ////////////////////////////// 21 ////////////////////////////// 22 ////////////////////////////// 23 ////////////////////////////// 24 ////////////////////////////// 25 ////////////////////////////// 26 ////////////////////////////// 27 ////////////////////////////// 28 //////////////////////////////
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1 Section 1028A(c), to wit, Bank Fraud, in violation of Title 18, United States Code, 2 Section 1344. 3 All in violation of Title 18, United States Code, Sections 1028A(a)(1), and 2. 4 5 6 A TRUE BILL: 7 DATED: 8 Signature of the Foreperson redacted pursuant to the policy of the Judicial Conference 9 FOREPERSON 10 11 JENNY A. DURKAN 12 United States Attorney 13 14 Carl Blackstone 15 Assistant United States Attorney 16 17 Kathryn A. Warma 18 Assistant United States Attorney 19 20 21 22 23 24 25 26 27 28
INDICTMENT/Seleznev, Roman. - 27 UNITED STATES ATTORNEY 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 (206) 553-7970
NATIONAL SECURITY ARCHIVE
National Security Archive, Suite 701, Gelman Library, The George Washington University, 2130 H Street, NW, Washington, D.C., 20037, Phone: 202/994-7000, Fax: 202/994-7005, nsarchiv@gwu.edu