Page:US District Court, Southern District of New York.-Liberty Reserve Indictment.pdf/21

derived from a criminal offense and intended to be used to promote and support unlawful activity.

(Title 18, United states Code, Sections 1960 s. 2.)

FORFEITURE ALLEGATION

43. As a result of committing one or more of. the offenses alleged in Counts one and Three of this Indictment, LIBERTY RESERVE, ARTHUR BUDOVSKY, a/k/a "Arthur Belanchuk," a/k/a "Eric Paltz," VLADIMIR KATS, a/k/a "Ragnar," AHMED YASSINE AEDELGHANI, a/k/a "Alex," ALLAN ESTEEAN HIDALGO JIMENEZ, a/k/a "Allan Garcia," AZZEDDINE EL AMINE, MARK MARMILEV, a/k/a "Marko," a/k/a "Mark Halls," and MAXIM CHUKHAREV, the defendants, shall forfeit to the United States, pursuant to Title 18, United States code, Section 9B2(a) (1), all property, real and personal, involved in the offenses and all property traceable to such property, including but not limited to:

a. A sum of money of at least $6 billion in United States currency;
b. All funds on deposit in the following accounts:

1. Banco Crédito Agrícola de Cartago (Costa Rica) Account No. 101527143, held in the name of LIBERTY RESERVE Sociedad Anonima;
2. Banco Crédito Agrícola de Cartago (Costa Rica) Account No. 101527141, held in the name of LIBERTY RESERVE Sociedad Anonima;
3. Banco Crédito Agrícola Ge Cartago (Costa Rica) Account No, l0l527144, held in the name of LIBERTY RESERVE Sociedad Anonima;