.. 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA, Case No.: 3:15-CR-00438-JO 

Plaintiff, 

v. 

WINSTON SHROUT, 

Defendant. 

SUPERSEDING INDICTMENT 

Counts 1 through 7 

18 U.S.C. § 514(a)(l) 

(Fictitious Obligations) 

Counts 8 through 10 

18 U.S.C. § 514(a)(2) 

(Fictitious Obligations) 

Counts 11 through 13 

18 U.S.C. § 514(a)(3) 

(Fictitious Obligations) 

Counts 14 through 19 

26 u.s.c. § 7203 

(Willful Failure to File Return) 

THE GRAND JURY CHARGES: 

Introductory Allegations 

At times relevant to this Superseding Indictment, 

Background 

1. Defendant Winston SHROUT was a resident of Hillsboro, Oregon. 

2. SHROUT operated a business using the name Winston Shrout Solutions in Commerce 

("WSSIC"). 

3. SHROUT received payments for services as a presenter at seminars, through which 

SHROUT promoted, among other things, the use of bonds as a means to pay off debts. 

4. SHROUT received licensing fees associated with the sale of SHROUT and WSSIC 

products, such as DVD recordings of seminars and private consultations with clients. 

SUPERSEDING INDICTMENT 

United States v. Shrout 1 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 1 of 12
5. SHROUT received regular pension payments from a pension trust. 

The Scheme and Artifice to Defraud 

6. Beginning in or about February 2008, and continuing through at least June 2015, 

defendant SHROUT knowingly devised and participated in a material scheme and artifice to 

defraud financial institutions and the United States out of funds and monies by making, 

presenting, and transmitting fictitious financial instruments, variously called, among other things, 

"International Bills of Exchange" ("IBOE") and "Non-Negotiable Bills of Exchange." SHROUT 

claimed that these fictitious financial instruments had monetary value when he knew those 

instruments were in fact worthless. During the course of this scheme to defraud, SHROUT 

produced and issued more than three hundred of these fictitious financial instruments, purported 

to be worth in total over $100,000,000,000,000 ($100 trillion), on his own behalf and for credit 

to third parties. 

Execution of the Scheme and Artifice to Defraud 

7. It was part of the scheme arid artifice to defraud that SHROUT produced fictitious 

financial instruments, which he falsely claimed had monetary value, when he knew they had no 

monetary value. 

8. It was further part of the scheme and artifice to defraud that SHROUT would produce 

these fictitious financial instruments naming himself as "Maker," "Drawer," or "Principal" and 

use a fabricated account number at the United States Department of Treasury, which number 

matched SHROUT's Social Security number. SHROUT would make and issue these fictitious 

financial instruments on behalf of himself and third parties. 

9. It was further part of the scheme and artifice to defraud that SHROUT would send these 

fraudulent and fictitious financial instruments and other documentation to financial institutions 

SUPERSEDING INDICTMENT 

United States v. Shrout 2 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 2 of 12
both within and outside the United States, as well as the United States Department of Treasury, 

via a private commercial carrier and the United States Postal Service, commanding the financial 

institutions and the Treasury Department to pay SHROUT and third parties through the 

fabricated account. 

10. It was further part of the scheme and artifice to defraud that SHROUT would provide 

verification procedures to third parties, through which he asserted the fictitious instruments were 

"obligations of the United States," "legal tender as a national Bank note, or note of a National 

Banking Association," and a "legal tender obligation of the United States." 

11. It was further part of the scheme and artifice to defraud that SHROUT generated personal 

income by promoting and marketing the use of fictitious financial instruments as a means to pay 

off debts, including federal income tax. SHROUT would provide handouts to seminar attendees 

that contained examples and templates for the creation of these fictitious financial instruments. 

12. It was further part of the scheme and artifice to defraud that SHROUT would have these 

seminars recorded and make recordings and handout materials available for purchase through his 

website: wssic.com. SHROUT marketed his materials and seminars through the website 

wssic.com and by direct marketing emails to existing clients for the purpose of generating 

income for himself. 

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United States v. Shrout 3 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 3 of 12
Counts 1 through 7 

18 U.S.C. § 514(a)(l) 

Fictitious Obligations 

13. The Introductory Allegations contained in Paragraphs 1 through 12 of this Superseding 

Indictment are re-alleged and incorporated herein as if copied verbatim. 

14. On or about the dates listed below, within the District of Oregon and elsewhere, 

WINSTON SHROUT, with the intent to defraud as to a material matter, drew, printed, 

processed, produced, published, and otherwise made and attempted to make within the United 

States, false and fictitious instruments, documents and other items appearing, representing, 

purporting, and contriving through material scheme and artifice to be actual securities and other 

financial instruments issued under the authority of the United States and an organization, to wit, 

documents titled "International Bill of Exchange" that were issued for credit to the entities listed 

below, in the amounts listed below, and bearing the serial numbers listed below, each instrument 

constituting a separate count of this superseding indictment: 

Count Date Made 

1 August 5, 2011 

2 December 14, 2011 

3 December 22, 2011 

4 January 20, 2012 

5 February 9, 2012 

6 February 27, 2012 

7 March 8, 2012 

SUPERSEDING INDICTMENT 

United States v. Shrout 

Purported For Credit To 

Value 

$1 billion Clarington Capital 

Group LLC 

$10 million Rainmaker Services 

Inc. 

$10 million A&P Management 

Corporation, S.A. 

$1 billion Capital International 

Investments Limited 

$500 billion World-Wide Funding, 

LLC 

$25 billion Asset International 

Funding 

$100 million America Pacific Global 

Exchange Corporation 

4 

Serial Number 

CCG10001 

RSI10B10002 

A&PlOM10004 

CIIL 1B10002 

WWF500B 10004 

AIF25B10001 

APGEC100M10006 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 4 of 12
All in violation of Title 18, United States Code, Section 514(a)(l). 

Counts 8 through 10 

18 U.S.C. § 514(a)(2) 

Fictitious Obligations 

15. The Introductory Allegations contained in Paragraphs 1through12 of this Superseding 

Indictment are re-alleged and incorporated herein as if copied verbatim. 

16. On or about the dates listed below, within the District of Oregon and elsewhere, 

WINSTON SHROUT, with the intent to defraud as to a material matter, passed, uttered, 

presented, offered, brokered, issued, sold, and attempted and caused to do the same within the 

United States, false and fictitious instruments appearing, representing, purporting, and contriving 

through material scheme and artifice to be actual securities and other financial instruments issued 

under the authority of the United States and an organization, to wit, documents titled and issued 

in the amounts listed below, bearing the serial numbers listed below, and presented to the entities 

listed below, each instrument constituting a separate count of this superseding indictment: 

Count Date Presented Document Title Purported Serial 

Value Number 

8 October 3, 2011 International Bill $1 trillion MGH10001 

of Exchange 

9 October 3, 2011 International Bill $1 trillion MGHllOOO 

of Exchange 

10 June 9, 2015 Non-Negotiable $1. 9 billion DMVlOOl 

Bill of Exchange 

All in violation of Title 18, United States Code, Section 514(a)(2). 

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United States v. Shrout 5 

Presented To 

American Metro 

Bank 

American Metro 

Bank 

United States 

Dept. of Treasury 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 5 of 12
Count 11 

18 U.S.C. § 514(a)(3) 

Fictitious Obligations 

17. The Introductory Allegations contained in Paragraphs 1 through 12 of this Superseding 

Indictment are re-alleged and incorporated herein as if copied verbatim. 

18. On or about October 3, 2011, within the District of Oregon and elsewhere, WINSTON 

SHROUT, with the intent to defraud as to a material matter, utilized interstate commerce, 

including the use of the mails, to transmit, transport, ship, move, transfer, and attempt and cause 

the same, through the United States, a false and fictitious instrument appearing, representing, 

purporting, and contriving through material scheme and artifice to be an actual security and other 

financial instrument issued under the authority of the United States and an organization. 

Specifically, SHROUT transmitted and caused to be transmitted via FedEx a document titled 

"International Bill of Exchange," issued in the amount of $1,000,000,000,000 ($1 trillion) and 

bearing the serial number MGHIOOOl, from Hillsboro, Oregon, to American Metro Bank in 

Chicago, Illinois. 

All in violation of Title 18, United States Code, Section 514(a)(3). 

Count 12 

18 U.S.C. § 514(a)(3) 

Fictitious Obligations 

19. The Introductory Allegations contained in Paragraphs 1 through 12 of this Superseding 

Indictment are re-alleged and incorporated herein as if copied verbatim. 

20. On or about October 3, 2011, within the District of Oregon and elsewhere, WINSTON 

SHROUT, with the intent to defraud as to a material matter, utilized interstate commerce, 

SUPERSEDING INDICTMENT 

United States v. Shrout 6 

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Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 6 of 12
including the use of the mails, to transmit, transport, ship, move, transfer, and attempt and cause 

the same, through the United States, a false and fictitious instrument appearing, representing, 

purporting, and contriving through material scheme and artifice to be an actual security and other 

financial instrument issued under the authority of the United States and an organization. 

Specifically, SHROUT transmitted and caused to be transmitted via FedEx a document titled 

"International Bill of Exchange," issued in the amount of $1,000,000,000,000 ($1 trillion) and 

bearing the serial number MGHl 1000, from Hillsboro, Oregon, to American Metro Bank in 

Chicago, Illinois. 

All in violation of Title 18, United States Code, Section 514(a)(3). 

Count 13 

18 U.S.C. § 514(a)(3) 

Fictitious Obligations 

21. The Introductory Allegations contained in Paragraphs 1 through 12 of this Superseding 

Indictment are re-alleged and incorporated herein as if copied verbatim. 

22. On or about June 9, 2015, within the District of Oregon and elsewhere, WINSTON 

SHROUT, with the intent to defraud as to a material matter, utilized interstate commerce, 

including the use of the mails, to transmit, transport, ship, move, transfer, and attempt and cause 

the same, through the United States, a false and fictitious instrument appearing, representing, 

purporting, and contriving through material scheme and artifice to be an actual security and other 

financial instrument issued under the authority of the United States and an organization. 

Specifically, SHROUT transmitted and caused to be transmitted via the United States Postal 

Service a document titled "Non-Negotiable Bill of Exchange," issued in the amount of 

$1,900,000,000 ($1.9 billion) and bearing the invoice number DMVIOOl, which was attached to 

SUPERSEDING INDICTMENT 

United States v. Shrout 7 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 7 of 12
a 2015 IRS Form 1040-ES Estimated Tax Payment Voucher, from Hillsboro, Oregon, to the 

Internal Revenue Service in Washington, D.C. 

All in violation of Title 18, United States Code, Section 514(a)(3). 

Count14 

26 u.s.c. § 7203 

Willful Failure to File Return 

23. The factual allegations contained in Paragraphs I through 5 of this Superseding 

Indictment are re-alleged and incorporated herein as if copied verbatim. 

24. During calendar year 2009, WINSTON SHROUT received gross income in excess of 

$18, 700. By reason of such gross income, he was required by law, following the close of the 

calendar year 2009, and on or before April 15, 2010, to make an income tax return to any proper 

officer of the Internal Revenue Service, stating specifically the items of his gross income and any 

deductions and credits to which he was entitled. Well knowing and believing all of the 

foregoing, he willfully failed, on or about April 15, 2010, in the District of Oregon and 

elsewhere, to make an income tax return. 

In violation of Title 26, United States Code, Section 7203. 

CountlS 

26 u.s.c. § 7203 

Willful Failure to File Return 

25. The Introductory Allegations contained in Paragraphs 1 through 5 of this Indictment are 

re-alleged and incorporated herein as if copied verbatim. 

26. During calendar year 2010, WINSTON SHROUT received gross income in excess of 

$18, 700. By reason of such gross income, he was required by law, following the close of the 

SUPERSEDING INDICTMENT 

United States v. Shrout 8 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 8 of 12
calendar year 2010, and on or before April 18, 2011, to make an income tax return to any proper 

officer of the Internal Revenue Service, stating specifically the items of his gross income and any 

deductions and credits to which he was entitled. Well knowing and believing all of the 

foregoing, he willfully failed, on or about April 18, 2011, in the District of Oregon and 

elsewhere, to make an income tax return. 

In violation of Title 26, United States Code, Section 7203. 

Count16 

26 u.s.c. § 7203 

Willful Failure to File Return 

27. The Introductory Allegations contained in Paragraphs 1 through 5 of this Indictment are 

re-alleged and incorporated herein as if copied verbatim. 

28. During calendar year 2011, WINSTON SHROUT received gross income in excess of 

$19,000. By reason of such gross income, he was required by law, following the close of the 

calendar year 2011, and on or before April 17, 2012, to make an income tax return to any proper 

officer of the Internal Revenue Service, stating specifically the items of his gross income and any 

deductions and credits to which he was entitled. Well knowing and believing all of the 

foregoing, he willfully failed, on or about April 17, 2012, in the District of Oregon and 

elsewhere, to make an income tax return. 

In violation of Title 26, United States Code, Section 7203. 

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Count17 

26 u.s.c. § 7203 

Willful Failure to File Return 

29. The Introductory Allegations contained in Paragraphs 1 through 5 of this Indictment are 

re-alleged and incorporated herein as if copied verbatim. 

30. During calendar year 2012, WINSTON SHROUT received gross income in excess of 

$19,500. By reason of such gross income, he was required by law, following the close of the 

calendar year 2012, and on or before April 15, 2013, to make an income tax return to any proper 

officer of the Internal Revenue Service, stating specifically the items of his gross income and any 

deductions and credits to which he was entitled. Well knowing and believing all of the 

foregoing, he willfully failed, on or about April 15, 2013, in the District of Oregon and 

elsewhere, to make an income tax return. 

In violation of Title 26, United States Code, Section 7203. 

Count18 

26 u.s.c. § 7203 

Willful Failure to File Return 

31. The Introductory Allegations contained in Paragraphs 1 through 5 of this Indictment are 

re-alleged and incorporated herein as if copied verbatim. 

32. During calendar year 2013, WINSTON SHROUT received gross income in excess of 

$21,200. By reason of such gross income, he was required by law, following the close of the 

calendar year 2013, and on or before April 15, 2014, to make an income tax return to any proper 

officer of the Internal Revenue Service, stating specifically the items of his gross income and any 

deductions and credits to which he was entitled. Well knowing and believing all of the 

SUPERSEDING INDICTMENT 

United States v. Shrout 10 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 10 of 12
foregoing, he willfully failed, on or about April 15, 2014, in the District of Oregon and 

elsewhere, to make an income tax retUrn. 

In violation of Title 26, United States Code, Section 7203. 

Count19 

26 u.s.c. § 7203 

Willful Failure to File Return 

33. The Introductory Allegations contained in Paragraphs 1 through 5 of this Indictment are 

re-alleged and incorporated herein as if copied verbatim. 

34. During calendar year 2014, WINSTON SHROUT received gross income in excess of 

$21,500. By reason of such gross income, he was required by law, following the close of the 

calendar year 2014, and on or before April 15, 2015, to make an income tax return to any proper 

officer of the Internal Revenue Service, stating specifically the items of his gross income and any 

deductions and credits to which he was entitled. Well knowing and believing all of the 

foregoing, he willfully failed, on or about April 15, 2015, in the District of Oregon and 

elsewhere, to make an income tax return. 

In violation of Title 26, United States Code, Section 7203. 

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United States v. Shrout 11 

Case 3:15-cr-00438-JO Document 17 Filed 03/15/16 Page 11 of 12
DATED this~ day of .MAf-Ci{, 2016. 

Presented By: 

BILLY J. WILLIAMS 

United States Attorney 

RYAN R. RAYBOULD 

Trial Attorneys 

U.S. Dept. of Justice, Tax Division 

SUPERSEDING INDICTMENT 

United States v. Shrout 

OFFICIATING FOREPERSON 

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