DMP/CRH:AAS/ANR F. #2022R00805 UNITED STATES DISTRICT

DMP/CRH:AAS/ANR

F. #2022R00805

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK

- - - - - - - - - - - - - - - - - - - - - - - - - - - X

UNITED STATES OF AMERICA

- against -

LU JIANWANG (卢建旺),

also known as “Harry Lu,” and

CHEN JINPING (陈金平)

Defendants.

- - - - - - - - - - - - - - - - - - - - - - - - - - - X

T O B E F I L E D U N D E R

S E A L

C O M P L A I N T A N D

A F F I D A V I T I N S U P P O R T

O F A R R E S T W A R R A N T S

(18 U.S.C. §§ 371, 1512(c)(1))

No. 23-MJ-265

EASTERN DISTRICT OF NEW YORK, SS:

JASON MORITZ, being duly sworn, deposes and states that he is a Special

Agent with the Federal Bureau of Investigation, duly appointed according to law and acting as

such.

CONSPIRACY TO ACT AS AN AGENT OF THE PRC GOVERNMENT

In or about and between January 2022 and the present, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the

defendants LU JIANWANG (卢建旺), also known as “Harry Lu,” and CHEN JINPING (陈

金平) together with others, did knowingly and willfully conspire to act in the United States as

agents of a foreign government, to wit: the People’s Republic of China (“PRC”), without prior

notification to the Attorney General of the United States, as required by law, contrary to Title

18, United States Code, Section 951(a).

(Title 18, United States Code, Section 371)

OBSTRUCTION OF JUSTICE

In or about October 2022, within the Eastern District of New York and

elsewhere, the defendants LU JIANWANG, also known as “Harry Lu,” and CHEN JINPING

did knowingly, intentionally and corruptly alter, destroy, mutilate and conceal a record,

document and other object, to wit: one or more electronic messages between the defendants

LU and CHEN and representatives of the PRC Ministry of Public Security (“MPS”) with the

intent to impair the object’s integrity and availability for use in an official proceeding, to wit:

a Federal Grand Jury investigation in the Eastern District of New York.

(Title 18, United States Code, Section 1512(c)(1))

The source of your deponent’s information and the grounds for his belief are as

follows:

1. I am a Special Agent with the Federal Bureau of Investigation (“FBI”).

Since becoming a Special Agent in 2018, I have participated in numerous counterintelligence

investigations, during which I have, among other things: (a) conducted physical and electronic

surveillance, (b) reviewed search warrant returns, (c) reviewed and analyzed recorded

conversations and records, and (d) debriefed cooperating witnesses and informants. I am

familiar with the facts and circumstances set forth below from my participation in the

Because the purpose of this Complaint is to set forth only those facts necessary

to establish probable cause to arrest, I have not described all the relevant facts and

circumstances of which I am aware.

investigation, my review of the investigative file, and reports of other law enforcement officers

involved in the investigation.

PROBABLE CAUSE

2. The investigation has revealed that the defendants LU JIANWANG,

CHEN JINPING and others have agreed to act as agents of the PRC government without prior

notification to the Attorney General. Since in or about 2015, LU has assisted the PRC

government by participating in counterprotests in Washington, D.C., against members of a

religion that is forbidden under PRC law and helping locate persons of interest to the PRC

government. More recently, LU, CHEN and others have operated an unofficial police station

in New York City on behalf of the Fuzhou Municipal Public Security Bureau (“FPSB”). The

FPSB is a provincial branch office of the MPS located in Fujian Province, PRC. When made

aware of the FBI investigation, LU and CHEN destroyed electronic evidence of their

communications with their primary liaison at the MPS (“MPS Official-1”), who had conspired

with LU and CHEN in the operation of the unofficial police station in New York City.

I. The Defendants and Coconspirators

3. The defendants LU JIANWANG and CHEN JINPING are among the

leaders of a nonprofit organization based in lower Manhattan that was established in 2013 and

lists its charitable mission as a “social gathering place for Fujianese people” (the

“Association”).

4. LU JIANWANG, also known as “Harry Lu,” is a U.S. citizen who

resides in the Bronx and currently serves as the General Advisor to the Association. LU is a

former president of the Association. LU also maintains a residence in the PRC.

5. CHEN JINPING is a U.S. citizen who resides in Manhattan. CHEN

currently serves as the Secretary General of the Association.

6. MPS Official-1 is the Director of the Overseas Chinese Affairs Office

within the FPSB. MPS Official-1 is a PRC citizen who is believed to reside in Fuzhou, Fujian

Province, of the PRC.

7. United Front Work Department of the Central Committee of the Chinese

Communist Party (“UFWD”) Official-1 is a senior official within the Fuzhou All-China

Federation of Returned Overseas Chinese, which is a known UFWD organization. UFWD

Official-1 is a PRC citizen who is believed to reside in the PRC. UFWD Official-1

introduced LU JIANWANG to MPS Official-1.

8. CC-1, a U.S. permanent resident and PRC citizen who resides in the

metropolitan New York area, appears to be a member of the Association.

9. CC-2, a U.S. citizen who resides in the metropolitan New York area and

was a leader of another local association in the metropolitan New York area.

II. The MPS and the UFWD

10. Based on my training and experience in investigating intelligence cases

involving the PRC as well as open-source materials, I am aware of the following: Although

the MPS is generally identified as the PRC’s primary domestic law enforcement agency—

responsible for public safety, general criminal investigation, national security and internet

security—its mission extends beyond law enforcement and into functions more associated with

an intelligence service. The MPS routinely monitors, among others, Chinese political

dissidents who live in the United States and in other locations outside the PRC. The MPS

has used cooperative contacts both inside the PRC and around the world to influence, threaten

and coerce political dissidents abroad. Indeed, I am aware that the PRC government has

threatened and coerced Chinese political dissidents living in the United States in an effort to

silence them.

11. According to an August 2018 report published by the U.S.-China

Economic and Security Review Commission, the UFWD coordinates the “United Front”

strategy to “co-opt and neutralize sources of potential opposition to the policies and authority”

of the Chinese Communist Party (“CCP”). The report further states the UFWD accomplishes

this using a range of methods, including “influenc[ing] overseas Chinese communities, foreign

governments, and other actors to take actions or adopt positions supportive of Beijing’s

preferred policies . . . United Front work serves to promote Beijing’s preferred global narrative,

pressure individuals living in free and open societies to self-censor and avoid discussing issues

unfavorable to the CCP, and harass or undermine Groups critical of Beijing’s policies.”

III. Regulations for Agents of Foreign Governments

12. An individual who acts in the United States as an agent of a foreign

government is required to provide prior notification to the Attorney General, under the rules

and regulations established by the Attorney General. See 18 U.S.C. § 951(b); 28 C.F.R. §§

73.1 et seq.

13. The term “agent of a foreign government” includes an individual who

agrees to operate within the United States subject to the direction and control of a foreign

government or official. See 18 U.S.C. § 951(d).

IV. Background of the Investigation

A. LU’s Relationship of Trust with the PRC Government

14. The investigation has revealed that LU JIANWANG has had a

longstanding relationship of trust with the PRC government and, in particular, the MPS and

the UFWD. LU admitted to the FBI during an interview—summarized in further detail

below—that, in 2015 during PRC President Xi Jinping’s visit to the United States, LU and

other leaders of local Chinese associations each sent 15 members to participate in

counterprotests in Washington, D.C., against public demonstrations against President Xi by

members of the Falun Gong religion.

LU further admitted to the FBI that he received a

plaque from the MPS celebrating work performed by local Chinese association leaders like

himself as part of the advance security team for President Xi’s entourage, in ensuring that

members of the Falun Gong religion did not disturb President Xi’s visit. A member of

President Xi’s entourage whose visa documentation reflected he was then “Deputy Director”

of the MPS (“MPS Official-2”) presented a plaque to LU in a ceremony. A picture of LU and

MPS Official-2 from that event is below.

The PRC government’s national security and law enforcement agencies regard political

dissent as a national security threat and monitor and censor political speech inconsistent with

CCP-approved political viewpoints, as well as speech that threatens to damage the reputation

of the PRC government or the CCP or threatens to undermine the PRC’s CCP-dominated social

order. The CCP’s “unapproved” topics include discussions about the overthrow of the CCP’s

control of the PRC government and the statuses of the Hong Kong and Taiwan. The modern

“Five Poisons” of the CCP—typically associated with Uighurs, Tibetans, adherents of Falun

Gong spiritual practice, pro-democracy dissidents and advocates for the independence of the

Taiwan—are especially sensitive topics to the CCP.

The images and names of the uncharged individuals shown in the photographs depicted

herein have been blurred.

15. The Falun Gong is a religious movement founded in the PRC during the

early 1990s that has been the subject of a worldwide crackdown by the PRC government.

According to the U.S. Department of State’s 2021 Report on International Religious Freedom,

“the [Chinese Communist Party] maintains an extralegal, party-run security apparatus to

eliminate the Falun Gong movement,” using methods ranging from harassment to

imprisonment. According to a report by the Safeguard Defenders, Falun Gong practitioners

outside of the PRC are also the subjects of intimidation by the PRC government and its allied

organizations.

16. In an interview with the FBI described in fuller detail below, LU

admitted an affiliation with the former Director of the MPS “610” directorate which handled

Falun Gong matters (“MPS Official-3”). In the same interview, LU admitted to participating

in counterprotests in Washington, D.C., against the Falun Gong organized by the PRC

government. Additionally, LU admitted to posing in the photograph below with MPS

Official-2 (depicted standing fifth from the left) and MPS Official-3 (depicted standing seventh

from the left) outside of LU’s home in the PRC.

17. In addition, since in or about 2018, LU JIANWANG and CC-1 have been

tasked by or assisted efforts by the PRC government, including the MPS, to identify the

locations of Chinese persons of interest in the United States.

18. For example, on or about July 15, 2018, CC-1 wrote LU JIANWANG a

message describing how a group of individuals defrauded others of money and fled to the

United States. At the time, LU was President of the Association. In relevant part, the

message indicated, “[Victim-1]’s passport number [] is already on file in China; [Victim-1] is

banned from leaving the country. But [Victim-1] used illegal means to get to [a third country],

and then from [the third country Victim-1] flew to the United States with his own green card.

President [LU JIANWANG], please see if there is any way to deport [Victim-1] back to China,

thanks.”

19. FBI agents have interviewed Victim-1, who confirmed that he/she has

been repeatedly harassed by a Chinese “Chamber of Commerce,” which Victim-1 identified

as the Association, to return to the PRC. Victim-1 also indicated that he/she had been

harassed by other U.S. based Chinese organizations. Victim-1 reported that the harassment,

which began in or around 2018—the same year as the tasking from CC-1 to LU

JIANWANG—has included repeated unsolicited telephone calls from purported members of

the Association and threats of violence to Victim-1 regarding family members of

Victim-1 residing in the United States, if Victim-1 refused to repatriate. Victim-1 also

indicated that members of his/her family in the PRC have been harassed by MPS officials since

Victim-1 arrived in the United States.

20. In or about 2020, CC-1 sent electronic communications to LU

JIANWANG requesting help in locating a PRC national who previously lived in Manhattan

(“Victim-2”). CC-1 sent LU Victim-2’s name, address as of 2016, and birthdate, before

instructing LU to identify any persons who are close associates with Victim-2. The

correspondence from CC-1 includes what appears to be a photograph surreptitiously taken of

Victim-2 sitting in a public park. CC-1 claimed that he/she needed the information in

connection with a lawsuit. Notably as discussed in further detail below, in 2022, MPS

Official-1 asked LU to help locate a PRC dissident residing in California and LU passed the

request on to CC-2.

B. The Overseas Police Station

21. In or about 2022, the FPSB established a New York based overseas

police service station (“Fuzhou Police Service Station for Overseas Chinese” or “FPSSOC”)

at the Association’s offices in lower Manhattan (the “Manhattan Premises”). None of the

persons working at the FPSSOC have provided prior notification to the Attorney General that

they would be working in the United States on behalf of the PRC government. A photograph

of the FPSSOC located at the Manhattan Premises is depicted below:

22. The investigation has revealed that, on or about January 10, 2022, the

FPSB officially launched an initiative with the goal of establishing overseas police service

station facilities worldwide in a ceremony held at Wuyi Square Park, Fuzhou, PRC. During

an interview with the FBI, summarized in further detail below, LU JIANWANG confirmed

attending this ceremony and acknowledged posing in the below photograph with MPS

Official-1:

In the photograph, LU JIANWANG and MPS Official-1 are holding a sign which reads,

“Fuzhou Public Security Bureau, Overseas 110 Report to Police Service Station.”

23. Interviews conducted by the FBI, including of LU JIANWANG and

CHEN JINPING, further confirmed that, on or about February 15, 2022, the FPSB—in

conjunction with the Association—established the FPSSOC. Additionally, review of

electronic media associated with the FPSSOC, as well as the FJSEN.com article cited below,

also revealed the below photograph—taken in February 2022—depicting seven Association

individuals/members (the “FPSSOC Principals”) who support FPSSOC operations in New

York City.

All translations from Chinese language to English are in draft form only and subject

to change.

“110” is a reference to the emergency phone number in the PRC—the equivalent of

“911” in the United States.

The picture includes a banner behind the FPSSOC Principals stating, “Fuzhou Police Overseas

Service Station, New York, USA.” The FPSSOC Principals in the picture include, among

others, the defendants LU JIANWANG and CHEN JINPING, located in the third-from-right

and second-from-right positions, respectively. According to queries conducted with the U.S.

Department of Justice in September 2022 and March 2023, none of the FPSSOC Principals

have notified the Attorney General that they are acting within the United States as agents of

the PRC government.

24. According to government records, LU JIANWANG was in the PRC

when the FPSB announced on January 10, 2022, the initial establishment of overseas police

stations (or “110 overseas stations”), which included 30 stations in multiple countries. Also,

according to government records, LU flew from Xiamen, PRC to Los Angeles, California on

February 13, 2022 before returning to New York City through John F. Kennedy International

Airport in Queens, New York. Notably, LU returned to the United States two days before

the FPSSOC opened in New York City on or about February 15, 2022.

25. While in the PRC, LU JIANWANG attended the Fifth Session of the 12

Fujian Provincial People’s Political Consultative Conference and the Sixth Session of the 13

Fujian Provincial People’s Congress from January 20 to 22, 2022. A May 2019

Congressional report on “China’s Growing Influence in Asia and the United States” describes

the People’s Political Consultative Conference as “the place where all the relevant united front

actors inside and outside the party come together. . . . They are gathered to receive instruction

in the proper propaganda lines and ways to characterize Beijing’s policies to both domestic

and foreign audiences.” LU’s identification card and plaque from the conference are depicted

below:

The identification card reads, “Fujian Provincial Political Consultative Conference 12

Session 5

Meeting, Attendee ID, Lu Jianwang.” The plaque reads, “Mr. Lu Jianwang:

Souvenir for attending Fujian Provincial Political Consultative Conference 12

Session 5

Meeting, Conference Secretariat Section, January 2022.”

26. Since the opening of the FPSSOC in or about February 2022, in at least

one instance, MPS Official-1 appears to have tasked the FPSSOC with helping locate a person

of interest to the PRC government.

27. I have reviewed electronic evidence that reveals that, on or about March

24, 2022, MPS Official-1 sent LU JIANWANG an electronic message directing LU to confirm

the location of an individual residing in California (“Victim-3”). MPS Official-1 provided

LU with Victim-3’s date of birth and name and address of a previous employer, as well as the

town in California where he/she believed that Victim-3 resided. MPS Official-1 wrote that

he/she had a friend who was looking for Victim-3 for personal reasons, and that there was no

need for LU to contact Victim-3 directly but that he should simply confirm his/her existence.

Notably, Victim-3 is a PRC dissident and PRC pro-democracy advocate who reported to the

FBI that he/she served as an advisor to a 2022 Congressional candidate from New York State

(the “Candidate”) who was a leader in the 1989 Tiananmen Square protests for political reform

in Beijing, PRC. The Candidate was also the victim of a charged PRC transnational

repression effort involving the Ministry of State Security.

See United States v. Qiming Lin,

22-MJ-251 (E.D.N.Y.).

28. After receipt of the tasking from MPS Official-1, LU JIANWANG left

a voice message for CC-2, asking CC-2 to find out if anyone “there” (in California) was

The Ministry of State Security is the foreign intelligence and secret police agency of

the PRC government responsible for counterintelligence, espionage and political security.

familiar with Victim-3, to confirm that information, and to let LU know before introducing

any such person to LU. CC-2 responded with a message that was later deleted.

29. I have spoken with Victim-3, who has indicated that he/she has been

harassed on multiple occasions by individuals whom he believes to be proxies for the PRC

government, including having his/her vehicle broken into immediately after he/she delivered

a pro-democracy speech, and receiving harassing telephone calls and electronic messages from

social media accounts that Victim-3 assesses to be associated with the PRC government.

C. The Media Reports

30. On April 30, 2022, the PRC media outlet FJSEN.com reported that the

FPSB, in coordination with the Association, established the FPSSOC on February 15, 2022.

The FJSEN.com article reported that the FPSSOC police service station helps Chinese citizens

living in the United States schedule applications to renew Chinese driver’s licenses via the

PRC-based encrypted messaging application WeChat. The FPSSOC police station then

electronically submits the application to the FPSB’s Traffic Management Center in Fuzhou,

PRC. After the PRC government has reviewed and approved the application, the applicant

may schedule an appointment at the Association for a virtual exam/interview with the FPSB.

31. On or about September 12, 2022, Safeguard Defenders, a pan-Asian non-

government human rights organization, published a report titled “110 OVERSEAS: Chinese

Transnational Policing Gone Wild.” According to the report, MPS Official-1 announced on

January 22, 2022, that the FPSB had opened its “first batch” of 30 overseas police service

stations or “110 overseas stations” in 25 cities in 21 countries. The report cited an article

from PRC news outlet chinanews.com that stated that, by June 2022, the FPSB had opened

another thirteen stations, bringing the total number of overseas stations to 38. The Safeguard

Defenders report states that the “110 overseas stations” are “[o]penly labeled as overseas police

service stations to accommodate the growing administrative needs of Fuzhou residents

abroad—for example in renewing Chinese driver’s licenses remotely and other tasks

traditionally considered of a consular nature,” but that they “also serve a more sinister goal as

they contribute to ‘resolutely cracking down on all kinds of illegal and criminal activities

involving overseas Chinese’” (emphasis in original).

32. On or about September 24, 2022—approximately twelve days after the

publication of the Safeguard Defenders article summarized above, FJSEN published an online

article about another overseas Chinese association and another undeclared overseas station

operating in the Manhattan Premises offering license renewal services. On the same day,

MPS Official-1 tasked CHEN JINPING with removing the article from the FJSEN website

(“handle that matter”) by sending a message to the individual who operates the website.

CHEN sent a screenshot of his correspondence with MPS Official-1 to the principal of FJSEN,

and the FJSEN principal confirmed to CHEN that he/she had removed the article.

D. The Judicially Authorized Search

33. On October 3, 2022, the FBI conducted a judicially authorized search of

the Manhattan Premises. Pursuant to the search, agents located an FPSSOC banner like the

one featured in some of the photographs depicted herein, as well as electronic equipment

consistent with renewing driver’s license applications.

No evidence of the other overseas police station was discovered during the search of

the Manhattan Premises.

36. Two of the FPSSOC Principals interviewed by the FBI in October 2022

were LU JIANWANG and CHEN JINPING.

LU JIANWANG

37. On October 4, 2022, the FBI interviewed LU JIANWANG near his

residence in the Bronx.

38. During the interview, LU JIANWANG explained that he was the

individual responsible for establishing the FPSSOC at the Manhattan Premises. While

visiting the PRC, LU JIANWANG was approached by UFWD Official-1, whom LU described

as a representative of the Fuzhou All-China Federation of Returned Overseas Chinese.

UFWD Official-1 informed LU JIANWANG that many overseas Chinese from Fuzhou could

not come back due to the pandemic and that it would be convenient to set up a service station

to renew Chinese government documents. UFWD Official-1 invited LU JIANWANG to a

meeting with FPSB Officials to discuss the establishment of the FPSSOC in countries across

the world. During this meeting, UFWD Official-1 introduced LU to MPS Official-1, an

individual whom UFWD Official-1 credited with establishing the overseas police stations

globally. LU JIANWANG stated that the FPSSOC was the first station established in the

United States and that he was aware that similar stations were operating in other countries.

39. According to LU JIANWANG, LU JIANWANG’s responsibility was to

stay in touch with the FPSB Officers and to start the FPSSOC. LU JIANWANG delegated

the responsibility to CHEN JINPING, Secretary General of the Association, who delegated the

responsibility to another FPSSOC Principal (the “Delegate”). LU JIANWANG admitted that

The Fuzhou All-China Federation of Returned Overseas Chinese is assessed to be a

UFWD-affiliated organization.

the FPSB directed LU JIANWANG, CHEN JINPING and the Delegate to provide five to six

people as points of contact in case the FPSB was unable to reach the Delegate. According to

LU JIANWANG, multiple names were provided to the FPSB as points of contact for the

FPSSOC, including those of CHEN JINPING, the Delegate and himself.

40. Though LU JIANWANG admitted to attending the initial meetings with

the FPSB in the PRC, he told the FBI that the details on how the FPSSOC would run were

directed to CHEN JINPING and the Delegate. LU JIANWANG described CHEN JINPING

and the Delegate as the primary points of contact with the FPSB, and the Delegate as

responsible for FPSSOC daily operations in New York. LU JIANWANG stated that there

was no formal agreement between the FPSSOC office in New York and the FPSB. Rather,

he claimed that the FPSB communicated directly with CHEN JINPING. LU JIANWANG

indicated that he believed the FPSB established a WeChat group for the FPSSOC in January

2022. Additionally, he stated that the FPSSOC hours of operation were every Thursday for

approximately two hours. LU JIANWANG claimed he was rarely present at the FPSSOC but

admitted to being present for photos. LU JIANWANG reiterated that he only initiated contact

with the FPSB, while CHEN JINPING coordinated with the FPSB, and the Delegate handled

the daily operations.

41. LU JIANWANG advised agents that he and MPS Official-1 were

members of a WeChat group titled “Fuzhou Overseas Chinese Service Group.” The group

was moderated by MPS Official-1 and had approximately 65 members. According to LU

JIANWANG, the WeChat group included other FPSB Officers. However, when asked if he

had communicated with anyone else from the FPSB, LU JIANWANG responded in the

negative.

42. LU JIANWANG claimed that, in or about September 2022, around the

same time that the Safeguard Defenders published its “110 Overseas” Report, MPS Official-1

notified both LU JIANWANG and CHEN JINPING via WeChat that he/she was going to

“pause” the New York FPSSOC. LU JIANWANG believed the true indicator that MPS

Official-1 shut down the FPSSOC was when MPS Official-1 shut down a second, smaller

overseas police service station WeChat group that included twelve people. LU JIANWANG

claimed it was possible the FPSB would want to restart the FPSSOC.

43. LU JIANWANG further admitted that he had deleted messages with

MPS Official-1 from his cellular device. When agents asked LU JIANWANG why he had

done so, LU JIANWANG claimed that he did not know why. After agents told LU

JIANWANG that deleting the messages seemed suspicious, LU JIANWANG apologized and

advised the agents that most of the conversations between himself and MPS Official-1

consisted of a disagreement between MPS Official-1 and the FPSSOC Principals about

whether the FPSSOC should charge money for services rendered. Previously, the FPSSOC

collected a $100 “donation” from each person who utilized the FPSB driver’s license service

at the FPSSOC. MPS Official-1 repeatedly asked the FPSSOC Principals over WeChat to

return the $100 “donation” to the individuals who paid it. LU JIANWANG further claimed

that he had not deleted any other messages recently. LU JIANWANG also claimed that his

deletion of the WeChat messages with MPS Official-1 was accidental.

44. During the interview, LU JIANWANG allowed agents to view his

WeChat messages with CHEN JINPING on his cellular device. In these messages, CHEN

JINPING sent screenshots of his conversation with MPS Official-1 to LU JIANWANG, in

which MPS Official-1 expressed that he/she was very upset that the FPSSOC had been

collecting money and directed the FPSSOC to return the funds by any means possible. MPS

Official-1 also indicated that the money needed to be returned as soon as possible before the

leaders found out. LU JIANWANG did not know which leaders MPS Official-1 referenced.

In the screenshots of the WeChat messages, MPS Official-1 further stated if the leaders found

out money had been collected it would not be viewed favorably. After CHEN JINPING

responded that finding WeChat IDs for the 51 donors would be hard, MPS Official-1 replied

the FPSSOC should have contact information for them because of the service provided.

45. At the conclusion of the interview, LU JIANWANG granted oral and

written consent to the FBI to seize and search his cellular device.

46. Following the interview, the FBI reviewed LU JIANWANG’s cellular

device. WeChat communications found therein reflect discussions amongst FPSSOC staff

regarding the facility’s operations, including the following:

a. On or about January 21, 2022, LU JIANWANG forwarded a

notice to CHEN JINPING stating “in order to establish a smooth connection to the remote

checkup identification renewal system every overseas service station has to grant access

privileges to the 110 system. Therefore please provide the service station IP address through

email to the following email address[].” LU JIANWANG requested CHEN JINPING handle

this task.

b. On or about January 28, 2022, LU JIANWANG invited CHEN

JINPING to a WeChat group called “First Batch of Overseas Service Centers.”

c. On or about January 29, 2022, CHEN JINPING asked if anyone

knew a business that could make banners and included as an example the banner from the

Portugal branch of the FPSSOC. LU JIANWANG responded the banners needed to be

custom made and recommended CHEN JINPING to speak with MPS Official-1. LU

JIANWANG provided MPS Official-1’s WeChat ID to CHEN JINPING, and CHEN JINPING

sent a screenshot of the initial contact to LU JIANWANG.

CHEN JINPING

47. On October 3, 2022, Special Agents from the FBI interviewed CHEN

JINPING at his residence in Manhattan.

48. CHEN stated he was not a worker or part of the staff of the Association.

CHEN JINPING denied any leadership role at the Association. He claimed he was not sure

of the relationship between the Association and the PRC government.

49. CHEN JINPING denied involvement with the Association multiple

times. CHEN JINPING conveyed to agents that he heard about the Association from WeChat

conversations. According to CHEN JINPING, someone had posted in a WeChat

conversation that the Association had helped them with Chinese driver’s license renewals.

When asked if he had contact with the PRC government about the license renewals, CHEN

JINPING stated he did not know the details. CHEN JINPING said he was part of large

WeChat groups and did not remember when this information was posted or who posted it.

50. CHEN JINPING was asked if the Association engaged in any other

business activities, and he replied he had only heard of the Chinese license processing. At

this time in the interview, CHEN JINPING was given a candor warning by the agents and

reminded that his interview with the FBI was voluntary.

51. CHEN JINPING claimed he did not have direct contact with the PRC

government. CHEN JINPING admitted he attended events at the PRC Consulate in New

York but claimed he did not know any of the officials.

52. In the interview, CHEN JINPING claimed to agents he did not know if

he had spoken to PRC officials on WeChat.

53. At approximately 9:06 a.m., CHEN JINPING went into the bathroom

while in possession of his cellular phone. An agent spoke to CHEN JINPING through the

bathroom door and advised him repeatedly not to delete anything from his phone. CHEN

JINPING left the bathroom at approximately 9:13 a.m. Thereafter, CHEN JINPING’s phone

was seized to prevent the destruction of evidence. On October 11, 2022, the government

obtained a judicially authorized search warrant for CHEN JINPING’s cellular phone.

54. FBI agents reviewed CHEN JINPING’s phone and found no WeChat

communications with MPS Official-1, despite the fact CHEN JINPING had sent screenshots

of his communications with MPS Official-1 to LU JIANWANG, as described above.

55. Based on my training and experience, electronic communications will

remain on an electronic device, such as a cellular telephone like CHEN JINPING’s, until they

are intentionally deleted. In addition, electronic devices, such as cellular telephones like

CHEN JINPING’s, have the capability of creating screenshots, which are photographic images

taken by the device of the image on the screen of that device when the screenshot is taken.

The metadata of a screenshot can reveal the date on which the screenshot was taken and the

device by which it was taken.

56. A review of photos found in CHEN JINPING’s phone uncovered a

screenshot with metadata indicating that it was taken by CHEN’s phone on October 1, 2022.

The screenshot shows WeChat communications between CHEN and MPS Official-1. The

presence on CHEN’s phone of this October 1, 2022 screenshot taken by CHEN’s phone of

WeChat communications supports the conclusion that CHEN deleted at least some of his

WeChat communications with MPS Official-1 on or after October 1, 2022. As noted above,

the FBI search of the Manhattan Premises occurred on October 3, 2022.

F. The December 2022 Interviews

57. In late December 2022, FBI agents again interviewed LU JIANWANG

and CHEN JINPING at their respective residences. In both interviews, the defendants

acknowledged deleting their communications with MPS Official-1 in response to the ongoing

investigation.

LU JIANWANG

58. On December 21, 2022, FBI agents interviewed LU JIANWANG at his

residence in the Bronx.

59. Shortly after beginning the interview, agents asked LU JIANWANG

whether he had deleted his WeChat communications with MPS Official-1 prior to meeting

with the FBI on October 4, 2022. LU JIANWANG responded, “I did not. I don’t think so.

I don’t remember.” When told that agents could not find the communications in LU

JIANWANG’s device, he indicated, “Sometimes my phone got stuck. Sometimes it

accidentally gets deleted when I am trying to unstick it. There was not much conversation

with [MPS Official-1] though. After I set up the center, I didn’t have contact with [MPS

Official-1].” He then admitted that he had communicated with MPS Official-1 extensively

during the establishment of the FPSSOC, as MPS Official-1 was his primary point of contact.

60. Agents showed LU JIANWANG several photographs located in his

device. LU JIANWANG identified multiple individuals in the photographs, including a

photograph of the opening ceremony with the five countries to first establish overseas police

service station locations. Among the individuals depicted in the photographs were

association presidents from Spain, France, Canada and the Netherlands, as well as the “Deputy

Chairperson” of the organization “Fuzhou All China Federation of Returned Overseas

Chinese.”

61. When asked about the timing of the ceasing of operations of the New

York FPSSOC, LU JIANWANG answered that MPS Official-1 instructed them to discontinue

collecting $100 from individuals who were utilizing the Chinese document services. When

asked why MPS Official-1 had caused the New York FPSSOC to cease operations after public

news disclosures about the international police stations, LU JIANWANG claimed, “I didn’t

know about the other stations. I only knew that our station could not charge [individuals].”

62. When asked if he or anyone from the Association requested that media

outlets, such as FJSEN, stop posting about the New York FPSSOC, LU JIANWANG

responded that the Association had received considerable attention after the FBI search. He

claimed he had not contacted any news outlets to stop the publication of articles.

63. Agents also asked LU JIANWANG whether he was aware of any direct

taskings from the MPS, including whether MPS Official-1 had ever asked him to locate

someone in the United States. As described above, electronic evidence reveals that MPS

Official-1 asked LU to confirm the location of Victim-3—a person identified by MPS Official-

1 to LU (and which LU then passed to CC-2; see supra paragraphs 27-28) as a California

resident—in or about March 2022. However, LU JIANWANG repeatedly denied receiving

such a request. When asked whether MPS Official-1 had ever asked LU JIANWANG or

other Association members to locate anyone in the United States, LU JIANWANG replied in

the negative. When asked specifically whether MPS Official-1 had provided LU

JIANWANG with a name of an individual in the United States, LU JIANWANG answered,

“No, [MPS Official-1] never did.” When asked whether MPS Official-1 had asked him to

locate an individual in California, LU JIANWANG said, “No, even if [he/she] asked me, I

wouldn’t do it because I don’t know these people. I am not sure, I cannot remember. I

wouldn’t do anything unlawful.” When asked more broadly whether the MPS had ever asked

him to locate anyone in the United States, LU JIANWANG responded, “I cannot be 100%

sure. They did ask me to get information on the Falun Gong.”

64. LU JIANWANG explained that he received a request regarding

counterprotests for the Falun Gong indirectly from the PRC Consulate in New York many

years ago when LU JIANWANG was president of the Association—a likely reference to the

work he performed in 2015 in connection with President Xi’s state visit. According to LU,

at the time, the PRCCONNY needed help counterprotesting the Falun Gong’s protest of PRC

President Xi Jinping’s state visit to the United States. The counterprotest was directed by a

senior official at PRCCONNY. LU was also asked to publish materials in newspapers against

the Falun Gong, but he claimed he did not do so. He elaborated as follows regarding his

activities concerning the Falun Gong:

Mostly the Consulate would ask associations to provide people

for welcoming and protesting. We have driven to D.C. on

buses. Each association member would receive $60 from the

Consulate. Each bus would have a point of contact that would

pay in cash from the Consulate. . . . People would not just travel

from New York but also from Philadelphia. Several hundred

people would go every time.

65. Agents showed LU JIANWANG a screenshot found in his phone of a

WeChat communication with MPS Official-1 in which MPS Official-1 asked LU JIANWANG

to return the mandatory $100 “donations” that the FPSSOC had been collecting. LU

JIANWANG acknowledged that his last communication in the chat with MPS Official-1 was

from October 2 or 3, 2022. In response to questioning regarding the deletion of chats with

MPS Official-1, LU JIANWANG replied: “I deleted it on mistake.” After further

questioning, LU JIANWANG acknowledged that he deleted the messages on October 3, 2022,

after hearing from other FPSSOC Principals that the FBI was conducting a search of the

Manhattan Premises and was interviewing FPSSOC Principals about the activities of the

FPSSOC.

CHEN JINPING

66. On December 22, 2022, FBI agents interviewed CHEN JINPING at his

residence in Manhattan.

67. When asked why he had lied about his participation in the Association

to FBI agents during his October 3, 2022 interview, CHEN claimed there had been a

misunderstanding with the agents during the previous interview. This time, CHEN

acknowledged his involvement with the Association and stated he served as Secretary General

of the organization. He stated that the position was mostly administrative in nature and he

was not part of the decision-making process of the organization. When asked if he had been

involved with the overseas police station, CHEN admitted that he had assisted with the

operation of the overseas station. CHEN stated that the FPSSOC assisted in the renewal of

Chinese driver’s licenses for PRC nationals living in the New York metropolitan area. CHEN

stated his belief that the FPSSOC had been providing help to people and that he never received

a monetary benefit or other type of benefit for assisting with the license renewals. He

confirmed the overseas station was run at the direction of the FPSB/MPS. CHEN believed

that the Chinese officials were affiliated with the traffic bureau of the MPS. According to

CHEN, after the FBI search on October 3, 2022, he realized that assisting with the collection

of personal information and passing this information to PRC government officials was

probably wrong and/or not a good idea because the FBI only investigates major crimes.

68. When asked with whom in the FPSB he communicated, CHEN indicated

that one of his two primary contacts included MPS Official-1. When asked which WeChat

groups were used for the FPSSOC, CHEN claimed that there were various WeChat groups that

included different participants that were started for different purposes. CHEN claimed he no

longer had access to these WeChat groups.

69. When asked when and why he had deleted his chats with representatives

from the FPSB, CHEN initially stated that he did not know when he had deleted the chats but

did so because the representatives were PRC government officials and he did not need the

chats. When asked again why and when he had deleted the WeChat messages CHEN,

admitted that he had done so “on or around the day he spoke with the FBI probably the day

after.” After agents provided a candor warning and advised him that he could not have deleted

the chats the day after the interview because the chats were not on the phone that the FBI had

seized from him, CHEN responded that he “did not remember” and then claimed that he had

done so “on or around the day he spoke with the FBI.” When asked if CHEN had deleted the

chats because he was afraid the FBI would find them, CHEN replied he deleted the chats

because, among other reasons, he knew the FBI would be interested in the communications on

the chats, including the participants in the chats and content of the chats. Agents asked CHEN

if he had deleted the WeChat communications while in the bathroom during his initial

interview. CHEN initially responded, “No.” Agents then showed CHEN application logs

from his device reflecting Tencent activity during the time he was in the bathroom. Notably,

Tencent is the developer of WeChat. Agents asked again if CHEN had deleted the WeChat

messages in the bathroom. CHEN admitted, “[i]t’s possible it happened in the bathroom” and

admitted that he had deleted both contacts and chats.

70. In response to further questioning, CHEN admitted that he had deleted

at least four different WeChat chat communications: (1) a “global” WeChat group chat that

included multiple associations throughout the world; (2) a “larger” New York WeChat group

chat that included many New York-based individuals; (3) a “smaller” New York WeChat

group chat that included identified individuals who were seeking help from the Association;

and (4) a chat with another MPS official. CHEN claimed there were no personal chats with

MPS Official-1. When shown a screenshot of a WeChat communication with another FPSB

official found in his cellphone, CHEN admitted that he had also deleted that chat.

71. CHEN claimed that the FPSSOC had ceased assisting with driver’s

license renewals prior to execution of the FBI search warrant at the Manhattan Premises, after

MPS Official-1 instructed the Association to stop activities because it had been collecting fees.

Agents asked whether MPS Official-1 had paused operations because of publication of news

articles regarding the New York FPSSOC. CHEN claimed that neither Association members

nor MPS Official-1 had referenced the news articles as a reason to cease activities.

72. Agents asked if CHEN ever caused news articles to be removed from the

Internet that discussed operation of the PRC overseas stations. CHEN admitted that he had

caused such an article to be removed from the FJSEN website by sending a message to the

individual believed to operate the website. As noted above, the article discussed another

overseas association using the Association office space for another overseas police station.

CHEN stated this other association was working with the Changle Public Security Bureau from