# Statement of Offense by Richard Pinedo

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
STATEMENT OF THE OFFENSE
Pursuant to Federal Rule of Criminal Procedure 11, the United States of America and the defendant, RICHARD PINEDO, stipulate and agree that the following facts are true and accurate. These facts do not constitute all of the facts known to the parties concerning the charged offense; they are being submitted to demonstrate that sufficient facts exist that the defendant committed the offense to which he is pleading guilty.
1. From approximately 2014 through December 2017, the defendant, RICHARD PINEDO, operated an online service called "Auction Essistance." Through Auction Essistance, Pinedo offered a variety of services designed to circumvent the security features of large online digital payment companies, including a large digital payments company hereinafter referred to as Company 1.
2. PINEDO sold bank account numbers through interstate and foreign commerce, specifically over the internet. PINEDO obtained bank account numbers either by registering accounts in his own name or by purchasing accounts in the names of other people through the internet. Many of the bank accounts purchased by PINEDO over the internet were created using stolen identities of U.S. persons. Although PINEDO was not directly involved in the registration ​of these accounts using stolen identities, he willfully and intentionally avoided learning about the use of stolen identities.
3. Company 1 required users to submit bank account numbers as a means of verifying a user's identity. To circumvent this requirement, certain users (hereinafter "Users") registered for Company 1's online services with bank account numbers in the names of other people. PINEDO sold Users bank account numbers over the internet to aid and abet, and in connection with, this scheme to defraud Company 1 by means of internet communications in interstate and foreign commerce.
4. After acquiring bank account numbers from PINEDO, Users linked the bank account numbers to their accounts with Company 1 as if they were the real owners of the bank accounts. Company 1 sought to verify the bank account numbers by making de minimus trial deposits into the accounts and asking Users to identity the amount of those trial deposits. PINEDO told Users the amounts of those trial deposits, thereby further aiding the Users in their scheme to circumvent verification processes by Company 1.
5. PINEDO frequently purchased bank account numbers from an individual he knew to be outside the United States. Similarly, based on IP addresses and other information, PINEDO knew that many of the persons to whom he sold bank account numbers were outside the United States.
DEFENDANT'S ACCEPTANCE
The preceding statement is a summary, made for the purpose of providing the Court with a factual basis for my guilty plea to the charge against me. It does not include all the facts known to me regarding the offense. I make this statement knowingly and voluntarily and became I am, in fact, guilty of the crime charged. No threats have been made to me, nor am I under the influence of anything that could that could impede my ability to understand the Statement of the Offense fully.
I have read every wont of this Statement of the Offense, or have bad it read to me. Pursuant to Federal Rule of Criminal Procedure 11, after consulting with my attorneys, I agree and stipulate 1o this Statement of the Offense and declare under penalty of perjury that it is true and correct.
ATTORNEYS' ACKNOWLEDGMENT
I have read this Statement of Offense, and have reviewed it with my client fully. I in my client's desire to adopt am stipulate to this Statement of the Offense as true and accurate.
This work is in the public domain in the United States because it is a work of the United States federal government (see 17 U.S.C. 105).
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