UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. _ ____ _ 

18 U.S.C. § 1343 

UNITED STATES OF AMERICA, 

vs. 

JOSE A. AMAN, 

Defendant. 

I ------------

INFORMATION 

The United States Attorney charges that: 

GENERAL ALLEGATIONS 

At all times relevant to this Information: 

1. Natural Diamonds Investment Co. (Natural Diamonds) was a Florida 

corporation with its principal place of business in Palm Beach , Florida. Natural Diamonds 

was purportedly in the business of buying and selling diamonds for retail and investment 

purposes . 

2. Eagle Financial Diamond Group Inc., a/k/a Diamante Atelier (Eagle) was a 

Florida corporation with its principal place of business in Palm Beach, Florida . Eagle was 

purportedly in the business of buying and selling diamonds for investment purposes. 

3. Argyle Coin , LLC (Argyle) was a Florida limited liability company, with its 

principal place of business in Palm Beach , Florida. Argyle was purportedly in the business 

of developing a cryptocurrency token backed by diamonds. 

20-80062-CR-Ruiz/Reinhart

KJZ Aug 21, 2020 West Palm Beach

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4. The defendant, JOSE A. AMAN , was the President of Natural Diamonds, Vice 

president of Eagle, and President of Argyle, and a signatory on the Natural Diamonds, Eagle 

and Argyle bank accounts. At most times relevant to the Information, Aman controlled the 

Natural Diamonds, Eagle and Argyle accounts and made all decisions regarding financial 

transactions on the accounts. 

COUNT 1 

(18 US.C. § 1343: Wire Fraud) 

5. The General Allegations section is re-alleged and incorporated as though fully 

set forth herein . 

6. From in or about May 2014, and continuing through in or about May 2019, in 

Palm Beach County, in the Southern District of Florida , and elsewhere, the defendant, 

JOSE A. AMAN, 

did knowingly, and with intent to defraud, devise and intend to devise a scheme and artifice 

to defraud and to obtain money and property by means of materially false and fraudulent 

pretenses , representations and promises, knowing that the pretenses , representations and 

promises were false and fraudulent when made, and for the purpose of executing such 

scheme and artifice to defraud , did knowingly transmit and cause to be transmitted by means 

of wire communications in interstate and foreign commerce, certain writings, signs, signals , 

pictures , and sounds. 

PURPOSE OF THE SCHEME AND ARTIFICE TO DEFRAUD 

7. It was the purpose of the scheme and artifice to defraud for the defendant, 

JOSE A. AMAN , to unlawfully enrich himself by fraudulently inducing individuals to invest 

millions of dollars in rough diamonds, and then using the fraudulently obtained monies to 

benefit himself, pay expenses , and further the fraud . 

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MANNER & MEANS OF THE SCHEME AND ARTIFICE TO DEFRAUD 

The manner and means by which the defendant sought to accomplish the object of 

the scheme and artifice to defraud included , among others, the following : 

8. The defendant entered into a business arrangement with partners to market 

and sell diamond investment contracts to the public, through Natural Diamonds and Eagle. 

The defendant was purportedly responsible for selecting and purchasing the diamond parcels 

and reselling them for a profit, and the partners were responsible for marketing the investment 

contracts and meeting with investors. The defendant and the partners held themselves out 

as experts in the diamond business . 

9. The defendant and the partners solicited individuals throughout the United 

States and Canada to invest in the diamond contracts. The solicitations were primarily 

through a radio show hosted by one of the partners , telephone calls , and word of mouth. 

10. To induce individuals to invest, the defendant and the partners promised (a) to 

use investors' money to purchase rough colored diamonds, which the defendant would cut, 

polish and resell at a profit, (b) to secure the investments with the defendant's inventory of 

diamonds, purportedly valued at $25 million, and (G) to pay investors significant returns, with 

no risk. 

11 . The defendant and the partners provided investors with written investment 

contracts which specified that the investments would take place over 24 or 18 months. For 

the 24 month investments, the investors would receive 2 percent monthly interest payments 

for 24 months, followed by the return of the principal. For the 18 month contracts, the 

investors would receive 100 percent returns , that is, double their initial investment, after 18 

months. 

12. In some instances, the contracts specified that the investor was purchasing a 

"certain rough diamond parcel," which the contract described and , in many instances, valued. 

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For example, one such contract indicated that the parties were partnering to purchase "a 

multi-colored diamond parcel with a majority of green diamonds ... valued at TWO MILLION 

($2,000,000) USD." The physical descriptions of the diamonds were often false and the 

values were always greatly inflated. 

13. To make it appear as if the investments were risk free , the defendant and the 

partners often included Promissory Notes with the investment contracts, which provided that 

Natural Diamonds would guarantee the investments . The Promissory Notes were false in 

that Natural Diamonds lacked the funds to guarantee the investments. 

14. The defendant and the partners caused the investors to send their investment 

funds to Natural Diamonds or Eagle via interstate wire or check . 

15. Contrary to the representations made to investors , the defendant rarely used 

investors' money to purchase the rough diamonds referenced in the investment contracts ; 

never cut, polished and resold any rough diamonds; did not have an inventory of diamonds 

valued at $25 million; and did not have the diamonds as described and valued in the contracts. 

16. To conceal the fraud from investors and create the appearance of legitimacy, 

the defendant made purported interest payments to the investors by using new investors' 

money to pay earlier investors. In some instances , the defendant used investment funds 

received from an Eagle investor to make purported interest payments to a Natural Diamonds 

investor. The defendant frequently commingled funds from the two companies and used 

whatever new money came into the companies to pay investors. 

17. At the end of the investment period , the defendant and the partners would 

induce the investors to roll over their investments. The defendant would falsely claim that 

the investor had the full value of his investment available to roll into a new investment and 

provided the investor with a "Re-Investment Contract." In truth, the Reinvestment Contract 

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was a sham as the defendant had already spent the investor's money and was simply trying 

to lull the investor and buy time to locate new investors and additional monies. 

18. When the scheme was about to collapse, the defendant set up Argyle Coin , 

LLC , which was purportedly in the business of developing a cryptocurrency token backed by 

diamonds. The defendant and a partner solicited new investors, as well as the existing 

Natural Diamond and Eagle investors to invest in Argyle. 

19. To induce individuals to invest in Argyle, the defendant claimed the investment 

would provide high rates of return with no risk because the investments were secured by $25 

million in diamonds and an insurance bond . In truth, the defendant did not have $25 million 

in diamonds or valid insurance contracts securing the investments and used only a fraction 

of the investors' money to develop a cryptocurrency token. Instead, the defendant used the 

Argyle investors' money to pay purported interest payments to the Natural Diamonds and 

Eagle investors and to benefit himself and the partners. 

20. During the course of the scheme, which spanned from May 2014 through May 

2019, the defendant and the partners collected approximately $30 million from investors, 

which money the defendant used to make purported interest payments to investors, to pay 

business expenses, to pay commissions to the partners, and to enrich himself and support 

his lavish lifestyle. 

USE OF THE WIRES 

21. On or about January 25, 2017, in Palm Beach County, in the Southern District 

of Florida and elsewhere, the defendant, 

JOSE A. AMAN, 

for the purposes of executing the aforesaid scheme and artifice to defraud and to obtain 

money and property from investors by means of materially false and fraudulent pretenses , 

representations and promises, did knowingly cause to be transmitted by means of wire 

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communications in interstate and foreign commerce certain writings , signs, signals, pictures, 

and sounds , that is, the defendant caused an investor (Victim 1) to wire transfer $200,000 

from his Scotiabank account in Alberta, Canada, to the Eagle account ending in 2439, at Bank 

of America , in Lake Worth , Florida. 

All in violation of Title 18, United States Code, Sections 1343 and 2. 

ARIAN FAJARDO ORSHAN 

UNITED STATES ATTORNEY 

ADRIENNE 

~~ RABINOWITZ 

ASSISTANT UNITED STATES ATTORNEY 

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

UNITED STATES OF AMERICA CASE NO. _______________ _ 

v. 

CERTIFICATE OF TRIAL ATTORNEY* 

JOSE A.AMAN 

Superseding Case Information: 

Defendant. 

Court Division: (Select One) 

Miami Key West 

New defendant(s) Yes 

Number of new defendants 

0 

FTL ✓ WPB FTP Total number of counts 

I. I have carefully considered the al legations of the indictment, the number of defendants, the number of 

probable witnesses and the legal complexities of the lndictment/lnformation attached hereto. 

2. I am aware that the information suppli ed on thjs statement will be relied upon by the Judges of tms 

Court in setting their calendars and scheduling criminal trials under the mandate of the Speedy Trial 

Act, Title 28 U.S.C. Section 316 1. 

3. Interpreter: (Yes or No) 

List language and/or dialect 

No 

4. Tms case will take _5_ days for the parties to try. 

5. Pl ease check appropriate category and type of offense listed below: 

(Check only one) (Check only one) 

I 0 to 5 days ✓ Petty 

II 6 to 10 days Minor 

Ill 11 to 20 days Misdem. 

rv 21 to 60 days Felony ✓ 

V 61 days and over 

6. Has this case previously been filed in this District Court? (Yes or No) 

If yes: Judge Case No. 

No 

-------------- (Attach copy of dispositive order) 

Has a complaint been filed in this matter? (Yes or No) 

If yes: Magistrate Case No. 

Related miscellaneous numbers: 

Defendant(s) in federal custody as of 

Defendant(s) in state custody as of 

Rule 20 from the District of 

ls this a potential death penalty case? (Yes or No) 

No 

7. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 

prior to August 9, 2013 (Mag. Judge Ali cia 0 . Val le)? Yes No ✓ 

8. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office 

prior to August 8, 20 14 (Mag. Judge Shaniek Maynard)? Yes No ✓ 

9. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 

pr;o, to Octobec 3, 20 I 9 (Mag. Judge Jared Straus:~ ~ 

ASSISTANT UNITED STATES TORNEY 

ADRIENNE RABINOWITZ 

*Penalty Sheet(s) attached REV 6/5/2020 

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: JOSE A. AMAN -----"_.;;;..;=..;;;;,=~=.=..;---------

Case No: --------------

Count #: 1 

Wire Fraud 

18 u.s.c. § 1343 

** Max. Penalty: Up to 20 years' imprisonment, 3 years' supervised release, $250,000 fine or 

twice the gross gain or loss resulting from the offense, whichever is greater, and restitution. 

*Refers only to possible term of incarceration, does not include possible fines, restitution, 

special assessments, parole terms, or forfeitures that may be applicable. 

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NUMBER: ----------

BOND RECOMMENDATION 

DEFENDANT: JOSE A. AMAN 

$25,000 Personal Surety 

(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention) 

By: ,~he: 

AUSA: ADRIENN E RABINOWITZ 

Last Known Address: __________ _ 

What Facility: 

Agent(s): S/A William Johnson 

(FBI) (SECRET SERVICE) (DEA) (IRS) (ICE) (OTHER) 

FBI 

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AO 455 (Rev. 0 1/09) Waiver of an Indictment 

UNITED STATES D ISTRJCT COURT 

United States of Ameri ca 

V. 

JOSE A. AMAN 

Def endant 

fo r the 

Southern District of Florida 

) 

) 

) 

) 

) 

Case No. 

WAIVER OF AN INDICTMENT 

I understand that I have been accused of one or more offenses punishable by imprisonment for more than one 

year. I was advised in open court of my rights and the nature of the proposed charges against me. 

Afte r receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by 

info rmation. 

Date: -------- Defendant 's signature 

Signature of defendant's attorney 

Kevin O'Reil l 

Printed name of defendant's allorney 

Judge 's signature 

Judge 's printed name and title 

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