33
but I’m not 100% sure. I have their contacts).”
G. Conclusion
66. Based on the foregoing, your affiant submits that there is probable cause to
believe that, from approximately January 2018 until the present, DIDENKO and others known
and unknown, have violated, caused to be violated, aided and abetted a violation, or conspired
to violate the following statutes:
a. DIDENKO and the remote IT workers caused false information to be transmitted to
U.S. government agencies located in the District of Columbia, to include the
Department of Homeland Security, the Internal Revenue Service, and the Social
Security Administration, thereby defrauding the United States by interfering with and
obstructing a lawful government function of these agencies by means of deceit, craft,
trickery, and dishonesty, in violation of 18 U.S.C. § 371.
b. DIDENKO and the remote IT workers devised a scheme or artifice to defraud
companies, or obtain money or property by means of false or fraudulent pretenses
from such companies, i.e., the employment of individuals using false identities, and
transmitted by means of interstate and foreign wires, specifically, through U.S.
Platform-1, U.S. Platform-2, U.S. MST-1, U.S. MST-2, the purpose of executing such
scheme or artifice, in violation of 18 U.S.C. §§ 1343 & 1349 (wire fraud and
conspiracy).
c. The remote IT workers, with assistance from DIDENKO, knowingly transferred,
possessed, or used, without lawful authority, a means of identification of another
person, while committing wire fraud, in violation of 18 U.S.C. § 1028A.