1 

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA, 

Plaintiff,

v. No. 22-cv-3304-ZMF

$299,218.48 IN UNITED STATES 

CURRENCY, 

Defendant.

MEMORANDUM OPINION

The United States seeks default judgment in its forfeiture suit against $299,218.48 involved 

in illicit sales to the Russian military in violation of the anti-money laundering statute, 18 U.S.C. 

§ 1956(a)(2)(A). For the reasons set forth herein, the Court will GRANT Plaintiff’s motion. 

I. BACKGROUND

A. The Defendant Currency

The government seeks to forfeit $299,218.48 paid by Techson Electronics, Inc. 

(“Techson”) for electronic parts that the government alleges were intended for illicit export to 

Russia. See Verified Compl. Forfeiture (“Compl.”), Decl. of Thomas Tamsi (“Tamsi Decl.”) 

¶¶ 21–23, ECF No. 1-1. In 2015, U.S.-based Global Circuit Innovations, Inc. (“GCI”) contracted 

to sell microchips manufactured by Altera Corporation to Techson for $648,000. See Tamsi Decl. 

¶¶ 8–9. Techson is a California-based company that acquires electronic parts in the United States

on behalf of Russian clients. See Tamsi Decl. ¶ 8. A Russian buyer paid Techson the $648,000

through an intermediary; Techson then paid GCI the funds. See Tamsi Decl. ¶¶ 13, 22. 
2

In April 2016, Techson asked GCI to send its Russian customer a sample of the Altera 

components. Tamsi Decl. at 5, ¶ 141. Altera shipped twenty-five components to a New York-based 

intermediary, UIP Techno Corp, which then shipped them to Russia. See id. The components at 

issue are covered by the Export Administrative Regulations, which require an exporter to file an 

accurate statement identifying the ultimate consignee or end user. See Tamsi Decl. ¶ 10; 15 C.F.R 

§ 30.6(a)(3). On May 4, 2016, Techson’s principal, Olga Andreyevskaya, signed documents 

attesting that the end user of the components was the Russian railway and that the parts would be 

used for commercial, civilian purposes. See Tamsi Decl. at 6, ¶ 14.

On May 18, 2016, GCI received an email from Nadezhda Marchenko at Aelek, a Russianbased company affiliated with the Russian military. See Tamsi Decl. at 6, ¶ 15, ¶¶ 17–19.

Marchenko wrote that she represented the end user and inquired about shipping times. See id. at 

6, ¶ 15. GCI forwarded the message to Andreyevskaya at Techson. Tamsi Decl. ¶ 16.

Andreyevskaya responded that she was “shocked” and that Marchenko was “not representative of 

end user.” Id.

In December 2016, U.S. Department of Homeland Security (“DHS”) agents interviewed 

two Russian nationals employed by Aelek who had been attempting to illegally export electronic 

components through UIP Techno. See Tamsi Decl. ¶¶ 17–19. The Aelek employees reported that 

Aelek was a subsidiary of Abtronics, a Russian military equipment manufacturer. See id. They 

confirmed that Marchenko worked for Aelek. See id. One employee reported that Marchenko 

taught him how to create falsified end user documentation for U.S. items purchased for export to 

1 The Tamsi Declaration inadvertently repeats paragraph numbers 14 and 15; references to either 

paragraph will include the page number for clarity. Later paragraphs are referenced as numbered

in the declaration. 
3 

Russia and that he doubted any end user statements prepared by Marchenko identified the true end 

user. See id.

On October 30, 2017, DHS seized $299,218.48—$648,000 less the funds GCI had already 

spent in performance of the contract—from GCI. See Tamsi Decl. ¶ 21. DHS then deposited the 

funds into a financial account managed by the Department of Treasury in Washington, D.C. See

Mot. Default & Order Forfeiture (“Mot. Default”), Mem. Law Supp. Mot. Default (“Mem. Supp.”)

4, ECF No. 26-1. 

B. Procedural History 

On October 28, 2022, the United States filed a verified complaint for forfeiture in rem

against the seized funds. See Compl. In December 2022, Techson claimed an interest in the funds 

and filed an answer to the complaint. See Claim, ECF No. 6; Answer, ECF No. 8.2 On June 16, 

2023, the United States moved to strike Techson’s verified claim and answer and for summary 

judgment for lack of standing. See United States’ Mot. Summ. J. Lack of Standing (“MSJ”), ECF 

No. 15. On March 4, 2024, the Court found that Techson lacked standing as an unsecured creditor 

and granted summary judgment. See United States v. $299,218.48 in U.S. Currency, No. 22-cv3304, 2024 WL 909927 (D.D.C. Mar. 4, 2024). No other claimants have claimed an interest in the 

defendant currency. 

On March 22, 2024, the government requested an entry of default by the Clerk of Court. 

See Request Default Entry by Clerk, ECF No. 24. On March 29, 2024, the Clerk of Court entered 

default. See Default, ECF No. 25. In turn, the United States moved for default judgment pursuant 

to Federal Rule of Civil Procedure 55. See Mot. Default. 

2 On February 6, 2023, the parties consented to proceed before a magistrate judge pursuant to Local 

Civil Rule 73.1 and 28 U.S.C. § 636(c). See Meet and Confer Report, ECF No. 11. 
4

II. LEGAL STANDARD

Federal Rule of Civil Procedure Rule 55 establishes a “two-step process” for obtaining 

default judgment. United States v. $1,071,251.44 of Funds Associated with Mingzheng Int’l 

Trading Ltd. (“Mingzheng”), 324 F. Supp. 3d 38, 44 (D.D.C. 2018). First, when a party has “failed 

to plead or otherwise defend” itself against the suit, the plaintiff may seek an entry of default by 

the Clerk of Court. Fed. R. Civ. P. 55(a). In forfeiture actions, this means that “unless a claimant 

properly intervenes to raise defenses to its forfeiture, the defendant property is deemed to have 

‘failed to plead or otherwise defend’ against the allegations, and the Clerk of Court must enter 

default.” United States v. All Assets Held in Acct. No. XXXXXXXX, 330 F. Supp. 3d 150, 156 

(D.D.C. 2018) (quoting Fed. R. Civ. P. 55(a)). “Once default is entered, the defendant ‘is deemed 

to admit every well-pleaded allegation in the complaint.’” United States v. Oil Tanker Bearing 

Int’l Mar. Org. No. 9116512, 480 F. Supp. 3d 39, 43 (D.D.C. 2020) (quoting Adkins v. Teseo, 180 

F. Supp. 2d 15, 17 (D.D.C. 2001)).

Second, the court may enter default judgment upon the party’s request. Fed. R. Civ. P. 

55(b)(2). “[T]he plaintiff is entitled to a default judgment only if the complaint states a claim for 

relief.” Mingzheng, 324 F. Supp. 3d at 45 (quoting Jackson v. Corr. Corp. of Am., 564 F. Supp. 2d 

22, 26–27 (D.D.C. 2008)). “Conceptually, a motion for default judgment is like a reverse motion 

to dismiss for failure to state a claim.” Id. (cleaned up). “That is, a complaint ‘must contain 

sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.’” 

Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks omitted)). In 

addition, the “higher standard of pleading” for forfeiture complaints contained in Supplemental 

Rule G(2), United States v. All Assets Held at Bank Julius Baer & Co., Ltd., 571 F. Supp. 2d 1, 16 

(D.D.C. 2008)—which requires the government to “state sufficiently detailed facts to support a 
5 

reasonable belief that the government will be able to meet its burden of proof at trial,” Supp. R. 

G(2)(f)—“may help to clarify when a civil forfeiture complaint” states a claim, Mingzheng, 324 

F. Supp. 3d at 46 (quoting United States v. $22,173.00 in U.S. Currency, 716 F. Supp. 2d 245, 249 

(S.D.N.Y. 2010)). 

III. DISCUSSION

Before granting default judgment, “a court should [first] satisfy itself that it has [] 

jurisdiction.” United States v. All Assets Held in Acct. No. XXXXXXXX, 330 F. Supp. 3d at 156 

(quoting Mwani v. Bin Laden, 417 F.3d 1, 6 (D.C. Cir. 2005)). Next, “the government must show 

that it complied with the notice requirements contained in the Supplemental Rules.” Mingzheng, 

324 F. Supp. 3d at 46. Finally, a court must assess the adequacy of the Complaint. See id. at 45. 

A. Jurisdiction and Venue 

This Court has jurisdiction pursuant to 28 U.S.C. § 1345 (“[T]he district courts shall have 

original jurisdiction of all civil actions . . . commenced by the United States . . . .”); 28 U.S.C. 

§ 1355(a) (“The district courts shall have original jurisdiction . . . of any action or proceeding for 

the recovery or enforcement of any . . . forfeiture . . . incurred under any Act of Congress . . . .”); 

and 18 U.S.C. § 981(a)(1)(A) (making “[a]ny property, real or personal, involved in a transaction 

or attempted transaction in violation of [18 U.S.C. § 1956], or any property traceable to such 

property” subject to forfeiture). See Compl. ¶ 4; see also Compl. ¶ 7 (alleging a violation of 18 

U.S.C. § 1956); Mingzheng, 324 F. Supp. 3d at 46. 

Next, 28 U.S.C. § 1355(b) confers in rem jurisdiction over the defendant property. That 

statute provides that “[a] forfeiture action or proceeding may be brought in . . . the district court 

for the district in which any of the acts or omissions giving rise to the forfeiture occurred.” 28 

U.S.C. § 1355(b)(1). “Traditionally, when exercising in rem jurisdiction, the defendant property 
6 

is physically present within the court’s territorial jurisdiction.” United States v. All Assets Held in 

Acct. No. XXXXXXXX, 330 F. Supp. 3d at 156. The defendant funds are located within this court’s 

territorial jurisdiction because DHS transferred them to an account in Washington, D.C. after their 

seizure. See Mem. Supp. at 4. Thus, the Court has in rem jurisdiction over the funds. 

Section 1355 also provides for venue in “the district court for the district in which any of 

the acts or omissions giving rise to the forfeiture occurred.” 28 U.S.C. § 1355(b)(1)(A). “As the 

Complaint details, the Defendant Funds are subject to forfeiture because the interested parties 

[submitted false end user documentation to U.S. Customs and Border Protection], which is located 

in Washington, D.C.” Mingzheng, 324 F. Supp. 3d at 46; see Tamsi Decl. ¶ 15. 

B. Notice Requirements

Supplemental Rule for Admiralty or Maritime Claims and Asset Forfeiture Actions (“Supp. 

R.”) G sets forth notice requirements in forfeiture actions. See Supp. R. G(4). The government 

must provide both general notice by publication and direct notice. See id. 

First, “[a] judgment of forfeiture may be entered only if the government has published 

notice of the action within a reasonable time after filing the complaint or at a time the court orders.” 

Supp. R. G(4)(a)(i). That notice must “(A) describe the property with reasonable particularity; 

(B) state the times under Rule G(5) to file a claim and to answer; and (C) name the government 

attorney to be served with the claim and answer.” Supp. R. G(4)(a)(ii). “Published notice must 

appear . . . once a week for three consecutive weeks,” Supp. R. G(4)(a)(iii), and may be 

accomplished by “posting a notice on an official internet government forfeiture site for at least 30 

consecutive days,” Supp. R. G(4)(a)(iv)(C). 

Less than one week after the government filed the Complaint, it published notice of the 

forfeiture action on www.forfeiture.gov for 30 consecutive days describing the defendant property, 
7 

the timeline to file a claim and answer, and the government attorney to serve. See Decl. Publication, 

ECF No. 19; See Request Default Entry by Clerk, Aff. of Rajbir S. Datta (“Datta Aff.”) ¶ 19. This 

satisfied the publication requirement in Supplemental Rule G. See United States v. Twenty-Four 

Cryptocurrency Accts., 473 F. Supp. 3d 1, 5 (D.D.C. 2020). 

Second, “[t]he government must send notice of the action and a copy of the complaint to 

any person who reasonably appears to be a potential claimant on the facts known to the government 

before the end of the time for filing a claim.” Supp. R. G(4)(b)(i). The notice must include the date, 

deadline for filing a claim and answer or Rule 12 motion, and name of the government attorney to 

be served. See Supp. R. G(4)(b)(ii). Such notice “must be sent by means reasonably calculated to 

reach the potential claimant.” Supp. R. G(4)(b)(iii)(A). 

The government identified all known potential claimants—Techson, LLC Normandia, and 

GCI— and mailed them direct notice between November 3, 2022 and December 8, 2022. See Datta 

Aff. ¶¶ 13–16. The government’s attorney attested that the mailed notice complied with 

Supplemental Rule G(4)(b). See id. This satisfied the direct notice requirement in Supplemental 

Rule G. See United States v. $3,435,935 of Funds From Al-Naser Airlines, No. 15-cv-1687, 2024 

WL 1141610, at *3 (D.D.C. Mar. 15, 2024). Thus, the government has satisfied all notice 

requirements in Supplemental Rule G. See id. 

C. Adequacy of the Complaint 

“Supplemental Rule G includes five relevant elements that must be included in a complaint 

in an action for forfeiture in rem. Four of these are largely formal, and one is substantive.” 

Mingzheng, 324 F. Supp. 3d at 48. Formally, “the complaint must be verified; state the basis for 

subject matter jurisdiction, jurisdiction over the property, and venue; describe the property with 

reasonable particularity; and identify the statute under which the forfeiture is sought.” Id. (citing 
8

Supp. R. G(2)(a)–(c), (e)). “Here, those provisions are met.” Id. The Complaint is verified, see 

Compl.; states the basis for jurisdiction and venue, see Compl. ¶¶ 4–6; describes the specific 

property, see Compl. ¶ 2–3; and identifies the statutes under which forfeiture is sought as 18 U.S.C. 

§ 981(a)(1)(A) and 18 U.S.C. § 981(a)(1)(A), see Compl. ¶ 7.

Substantively, the Complaint must “state sufficiently detailed facts to support a reasonable 

belief that the government will be able to meet its burden of proof at trial.” Supp. R. G(2)(f). As

set forth by the government, the defendant funds are the remainder of the funds paid to GCI by 

Techson on a contract for electronic parts that were intended for shipment to Russia. See Tamsi 

Decl. ¶ 21. The parts were covered by the Export Administrative Regulations, which require the 

exporter to file information accurately identifying the parts’ ultimate consignee or end user. See 

Tamsi Decl. ¶ 10. Techson’s principal signed documents identifying the end user as a company 

affiliated with the Russian Railway. See Tamsi Decl. at 6, ¶ 14. However, an individual (Nadezhda 

Marchenko) at a different Russian company (Aelek) then got in contact with GCI, claiming to be 

the parts’ end user. See Tamsi Decl. at 6, ¶ 15. Although Techson’s principal claimed that she was 

“shocked” at Marchenko’s assertion of ownership, see Tamsi Decl. ¶ 16, separate information 

revealed Marchenko to be practiced at falsifying end user documentation and to be affiliated with 

the Russian military, see Tamsi Decl. ¶¶ 18–20. A Russian witness who worked with Marchenko 

claimed that she trained him to prepare falsified end user documentation for items purchased in 

the United States and that he doubted any end user statements prepared by Marchenko’s company 

identified the exports’ true end user. See Tamsi Decl. ¶ 17–19. Techson and Marchenko also relied 

on the same New York-based intermediary. See Tamsi Decl. at 5, ¶ 14, ¶¶ 17–19. For her part, 

Techson’s principal told DHS in an interview only that she had conducted the transaction at issue 
9

at the direction of a third party who assisted her company in finding Russian customers for 

American merchandise. See Tamsi Decl. ¶ 22.

These facts support a reasonable belief that the government would have been able to meet 

its burden of proof at trial. See Supp. R. G(2)(f). The International Emergency Economic Powers 

Act (“IIEPA”) criminalizes willful violations of a regulation issued under the IEEPA. See 50 

U.S.C. § 1705(a). One such regulation instructs that “[n]o person may make any false or 

misleading representation, statement, or certification . . . [i]n connection with the preparation, 

submission, issuance, use, or maintenance of any ‘export control document’ or any report filed or 

required to be filed pursuant to the EAR.” 15 C.F.R. § 764.2(g)(1)(ii). And the international money 

laundering statute prohibits the transfer of currency from outside to inside the United States with 

the intent to promote violations of the IEEPA. See 18 U.S.C. § 1956(a)(2)(A). The government 

could reasonably prove at trial that the initial transfer of funds came from Techson’s buyer in 

Russia to Techson in the United States and promoted a violation the IEEPA: the end user 

documentation prepared by Techson’s principal was false and misleading by listing a falsified end 

user, violating 15 C.F.R. § 764.2(g)(1)(ii). The defendant funds are the portion of those funds that 

remained in GCI’s possession after it attempted to fulfill the contract. See Tamsi Decl. ¶ 21. Thus, 

the defendant funds are “property . . . involved in a transaction or attempted transaction in violation 

of [the international money laundering statute, 18 U.S.C. § 1956], or any property traceable to such 

property,” 18 U.S.C. § 981(a)(1)(A), so are “subject to forfeiture to the United States,” 18 U.S.C. 

§ 981(a)(1).
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IV. CONCLUSION

The government has 99 problems, but $299,218.48 isn’t one.

Date: July 16, 2024

___________________________________

ZIA M. FARUQUI

UNITED STATES MAGISTRATE JUDGE