UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED 
STATES 
DI
STRICT 
COURT 
SOUTHERN 
DI
ST
RlCT 
OF 
NJ::W 
YORK 
UNITED 
ST 
A 
TES 
OF 
AMERICA 
V. 
GANNON 
KEN 
VAN 
DYKE
, 
Defendant. 
OR
I
GINAL 
lND
l CTMENT 
26 
Cr
. 
Ii 
h 
COlJNTONE 
(Unlaw
f
ul 
Use 
of 
Con
fi
de
ntial Gover
n
me
nt I  n
format
i
on 
fo r 
Perso
nal 
Gain) 
The 
Grand 
Jury 
charges: 
1. 
GANNON 
KE 
VAN 
DYKE, 
the 
de
fendan
t, 
misappropria
t
ed 
cbssHicd, 
nonpubl
ic 
U.S. 
Government 
information 
about 
a 
U.S. 
military 
operation 
to 
capture 
Nico
las 
Maduro 
and 
his 
wi
fe, 
Cilia 
Flores, 
called 
"Operation 
Abso
lute 
Resolve
," 
to 
make 
more 
than 
$400,000 
in 
illeg
al 
profits. 
Al 
the 
time, 
VAN 
DYKE 
was 
an 
active-duty 
membe
r 
of 
the 
U.S. 
Am1y 
and had 
access 
to sensit
i
ve
, 
nonpublic, 
classified 
infonnation 
about 
the 
operation 
prior 
to 
its 
pub
lic 
disclosure. 
Rather 
than 
safeguar
d t
ha
t 
lnfonnation 
as 
he 
was 
obligated 
to 
do, 
VAN 
DYKE 
de
cided 
to 
use 
that 
classified 
infonnation 
lo 
place 
trades 
on 
a. 
prcd
ictjon 
market 
plallorm 
fo
r 
his 
pers
onal 
pro6t. 
VA 
DYKE 
subsequen
tl
y t
ri
ed 
to 
conceal 
his 
unlawfu
l 
use 
of 
classified 
U 
.. 
Government 
information 
by 
attempting 
to 
obscure 
the 
source 
of 
his 
unlawfu
l  proceeds 
and 
to 
disguise 
his 
connection 
to 
the 
accou
n
ts 
linked 
to 
the 
il
licit 
tr
ades. 
VAN 
DYKE 
Gained 
Access 
co 
Class
ified 
information 
About 
Operation 
Abso
l
ute 
Re
so
lv
e 
2. 
Since 
in 
or 
abo
ut 
2008
, 
GANNON 
KEN 
VAN 
DYKE, 
the 
defendant, 
ha
s been 
an 
active-duty 
sol
die
r 
in 
the 
U.S. 
Ann
y. 
Since 
at 
least 
in 
or about 
2023, 
VA 
DYKE 
h
as 
been 
a 
Ma
ster 
.. 
ergea
nt 
wi
th 
U.S. 
Army 
Speciw 
Forc
es. 
At 
times 
relevant 
t o 
this 
Indi
ctment
, 
VAN 
DYKE 

was 
stationed 
at 
Fort 
Bragg, 
a 
mi
litary 
base 
located 
in 
Fayetteville
,  North 
Caro
lina
.  Fort 
Bragg 
houses 
the 
82
nd 
Airborne 
Division
,  XVIII 
Airborne 
Corps, 
U.S. 
Anny'
s 
Special 
Operations 
Co
mmand 
("USASOC")
, and 
the 
Joint Special 
Operations 
Command 
("JSOC,,). 
JSOC 
is a unified 
command 
assigned 
to 
the 
United 
States 
Special 
Operations 
Command 
that 
prepare
s  assigned, 
attached, 
and 
augmentation 
forces 
and, 
when 
directed
, conducts 
special 
operations 
aga
inst 
threats 
to 
protect 
the 
homeland 
and 
U.S. 
interests 
abroad. 
3. 
In 
or 
about 
September 
2018, 
GANNON 
KEN 
VAN 
DYKE
, the 
defendant, 
signed 
a 
Sensitive 
Co
mpartmented 
Information 
("SC
I") 
Nondisclosure 
Agreement. 
Under 
that 
agreement
,  VAN 
DYKE 
acknow
ledged 
that 
the 
United 
States 
Government 
placed 
"s
pecial 
confidence 
and 
trust" 
in VAN 
DYKE. 
Under 
that 
agreement
, VAN 
DYKE 
also 
promised 
to 
"never 
diYl.ll
ge 
anything 
marked 
as 
SCI 
or 
that 
[he] 
know[s] 
to 
be 
SCI 
to 
anyone." 
VAN 
DYKE 
further 
acknow
ledged 
that 
"all 
information" 
to 
which 
he 
may 
"obtain 
access 
... 
is  now 
and 
will 
remain 
the 
property 
of 
the 
United 
States 
Government.
"  Acco
rdingly, 
since 
in 
or 
about 
that 
time, 
VAN 
DYKE 
has 
had 
access 
to sensitive, 
nonpub
l
ic
, cla
ssified 
information. 
4. 
On 
or 
about 
December 
8,  2025, 
GANNON 
KEN 
VAN 
DYKE
,  the 
defendant
, 
signed 
a  nond
isclosure 
agreement 
regarding 
Western 
Hemisphere 
Operations. 
Pursuant 
to 
the 
terrns 
of 
the 
agreement, 
VAN 
DYKE 
acknow
ledged 
that
, due 
to 
his 
associat
i
on 
with 
USASOC, 
he 
may 
be 
granted 
access 
to 
"information
,  material
,  and 
plan
s, 
which 
concern 
the 
security 
of 
the 
United 
States
," 
and 
VAN 
DY.KE 
agreed 
he 
would 
"never 
divulge, 
publish, 
or 
reveal 
by 
writing
, 
words, 
conduct, 
or 
otherwise 
. . .  any 
cla
ssified 
or 
sensitive 
information 
relatin
g to 
[USASOC] 
operations 
within 
the 
Western 
Hemisphere." 
VAN 
DYKE 
further 
agreed 
that 
classified 
or 
sensitive 
information 
he 
acquired 
in 
connect
ion 
with 
his 
association 
with 
"USASOC 
operations 
within 
the 
Western 
Hem
isphere 
remains 
the 
property 
of 
the 
Government 
of 
the 
United 
States 
of 
America.
" 
2 

5. 
From 
at 
least 
on 
or 
about 
December 
8, 2025
, through 
at 
least 
on 
or 
a bout 
January 
5, 
2026, 
GANNON 
KEN 
VAN 
DYKE
, 
the 
defendant, 
was 
involved 
in 
the 
planning 
and 
execution 
of 
Operation 
Abso
lute 
Reso
lve, 
and 
bad 
access 
to 
sensitiv
e, 
non-pub
lic, 
classified 
information 
about 
that 
operation. 
6. 
GANNON 
KEN 
VAN 
DY
KE, 
the 
defendant
, was 
aware 
that 
his 
association 
with 
USJ\SOC 
provid
ed 
him 
access 
to 
classified 
U.S. 
Government 
informat
ion. 
In 
or about 
November 
2025
, VAN 
DYKE 
uploaded 
to 
h is Google 
accoun
t a screenshot 
disp
laying 
the 
results 
of 
a Google 
Al 
query
. Th
e  results 
stated, 
in 
substance 
and 
in 
part, 
that 
the 
U.S. 
military'
s 
special 
operations 
divi
sions 
have 
"numerous 
classified 
fi
les, 
records, 
and 
operational 
details 
that 
are 
not 
available 
to 
the public;'' 
and 
"[e]ve
n  when 
some 
informa
t ion 
is 
releas
ed 
... 
,  many 
sensitive 
detai
ls, such 
as 
s pecifi c  sourc
es, 
methods
,  and 
full 
operationa
l  time
line
s, 
are 
consistently 
withheld 
to 
prote
ct 
nationa
l sec
urity 
intere
sts and 
future 
operations." 
Po
lymarket 
Contracts 
Concern
i
ng 
Venezue
la and 
Maduro 
7. 
Polymarket 
is the 
trade 
name 
of 
a prediction 
market
place 
operated 
by 
Blockrat
ize, 
Inc. 
Po
lymarket 
is 
headquarte
red 
in 
Manhattan, 
New 
York. 
Po
lymarket 
o ffers  hundreds 
of 
"rna
rket
s"-
ref
erred to 
as 
binary 
event 
contracts
, 
or 
"shares
"-
that 
allow 
user
s to 
wager 
on  the 
outcome 
of 
future 
events 
across 
categories 
inc
.Judin
g  current 
e vents, 
politics
, 
.s
ports, 
a
nd 
pop 
culture. 
Markets, 
includin
g those 
relevant 
he
re,. are 
created 
by 
Po
lyrnarket 
personne
l before 
bein
g 
pub
lished
. Each 
market 
is framed 
as 
a Yes/No 
question 
such 
as 
"W
il
l X 
happen?" 
and 
pairs 
a YES 
shar
e wit
h a 
NO 
share
. At 
resolution, 
the 
share 
on 
the 
co
rrect 
side pays 
$1.00; 
the 
other 
pays 
$0
.00
. 
Shares 
trad
e  between 
$0.00 
and 
$ l .00
,  and 
the 
share 
price 
reflect
s  the 
market's 
rea
l-tim
e 
assessment 
of 
the 
probability 
that 
an 
eve
nt 
w
ill 
occur
. For 
examp
le
, 
if 
the 
mark
et perceiv
es 
a  75% 
3 

probabi
lity, 
the 
YES 
share 
will 
trade 
at 
approximate
ly $0.75 
and 
the 
NO 
share 
at 
approximately 
$0.25, 
and 
the 
prices 
adjust 
as 
countcrparty 
sup
ply 
and 
demand 
shift. 
8. 
Po
lymarket's 
website 
is  accessible 
via 
th
e internet 
throughout 
the 
wor
ld, 
inc
luding 
in the 
Sou 
them 
District 
of 
New 
York. 
Polymarkct 
operates 
mark 
els, including 
those 
relevant 
here, 
using 
the Polygon 
blockchain 
and 
it 
processes 
tr
ad
ing 
activity 
and 
payments 
in the 
cryptocurre
ncy 
''USDC.c," 
a stab
lcco
in pegged 
1:1 
to 
the 
U.S. 
dollar. 
The  Polymarket 
markets 
relevan
t 
here 
are 
published 
to 
the 
Po
lygo
n blockchain 
as 
a 
smart 
co
ntract
-a 
self-execu
ting 
di
gital 
agreement
-
that 
automatica
lly disperses 
US
DC.e 
to 
th
e hold
ers 
of 
winn
ing 
share
s when 
a market 
reso
lves. 
9. 
In 
or 
about 
the 
fall 
and 
winte
r 
of 
2025, 
Polymark
et 
began 
offering 
binar y  event 
contracts 
related 
to 
whether 
ce
rtain 
even
ts  invo
lving 
Venezuela 
and 
Nico
las 
Maduro 
would
,  or 
would 
not, 
occur
.  On 
or 
a bout 
September 
6,  2025, 
Polymarket 
posted 
a  market 
offer
ing  event 
contracts 
rega
rdin
g 
th
e 
li
ke
lihood 
of 
"US 
forces 
in 
Venezue
la 
by" 
certain 
dates, 
includin
g 
September 
6, 
2025; 
October 
31, 
2025; 
Nove
mb
er 30, 
2025; 
December 
31, 
2025; 
January 
3 1, 2026; 
or 
March 
3 1,  2026. 
On 
or 
about November 
3, 
2025, 
Pol
ymarket 
posted 
a  market 
offering 
eve
nt 
contracts 
regardin
g  the 
future 
like
lihood 
of 
Maduro 
bein
g 
"o
ut" 
of 
or 
removed 
from 
power 
in 
Venezuela 
by 
certain 
dates, 
including 
November 
30, 
2025; 
December 
31
, 2025; 
January 
3 1, 2026; 
February 
28, 
2026
;  March 
3 1,  2026; 
or  December 
3 1,  2026. 
On 
or 
about 
Decembe
r  17, 
2025, 
Po
lymarket 
posted 
a market 
offer
ing eve
nt 
contracts 
regard
ing  the 
future 
like
li
hood 
of 
the 
U.S. 
invading 
Venezue
la 
by 
on 
or 
before 
January 
31, 
2026. 
On 
or 
about 
December 
18, 
2025, 
4 

Polymarket 
po
sted 
a market 
offering 
event 
contract
s  rega
rdin
g  the 
futur
e  likelih
oo
d 
of 
Pre sident 
Trump 
" invok[in
gl 
War 
Powers 
against 
Venezuela" 
by a certain 
date
. 
VAN 
DYKE 
Mak.
es 
Polymark
et Trad
es 
on 
Venezuela 
and 
Maduro 
Relat
ed Markets 
10. 
On 
or  abou
t  Dec
em
ber  26, 
2025, 
GANNON 
KEN 
VAN 
DYKE
,  the  defendant
, 
creat
ed a  Pol
yrnarket 
acco
unt. 
VAN  D
YKE 
used a  virtual 
privat
e  notwork 
(''V
PN") 
service 
and 
connec
ted 
to  Po
lymarket 
th
rough 
an 
exit 
node, 
wh
ich 
geo
locate
d  t
o  a  fore
ign 
co
un
try.  Then, 
between 
on 
or 
about 
Decem
ber 
27, 
2025, 
and 
on 
or  about 
January 
2, 
2026, 
at 
approximately 
9:58 
PM 
EST, 
VAN 
DYKE 
pur
c
ha
sed 
approximatel
y $33,934 
worth 
of"YES" 
shar
es 
on M
aduro-
and 
Venezue
la-r
ela
ted markets. 
11. 
Sp
ecifically
, GANNON 
KEN 
VAN 
D YKE, 
the 
defendant
, traded 
on 
Madur
o-
and 
Ve
nezuela-r
elated 
contra
cts 
on 13 
separat
e  oc
ca
sions: 
a. 
On 
or about 
Dec
emb
er  27, 
2025
, VAN 
DYKE 
purchased 
approximate
ly 
634 
"YE
S" 
shar
es 
of 
th
e market 
"U.S. 
Forces 
in 
Venezuela 
... 
by 
January 
3
1, 
2026'' 
at a vo
lum
e-
weighted 
average 
pri
ce 
of 
approximately 
$0
, 
l 5 
pe
r 
share, 
for 
a 
total 
purchase 
price 
of 
approxima
te
ly 
96 
US
DC.e  (ap
pr
ox
imat
ely 
$96). 
b. 
On 
or 
about 
De
cember 
30, 
2025, 
VAN 
DYKE 
purchased 
appr
oxima
te
ly 
13
,769 
"YES" 
share
s 
of 
the 
market 
"M
aduro 
o ut by 
... 
January 
3 l , 2026" 
at 
a vo
lume-w
eighted 
average 
price 
o f approxima
tely 
$0
.09 
per 
share
, for 
a total 
pur
c
ha
se 
pri
ce 
of 
approximately 
l ,23
8 
USDC.e 
(ap
proximat
ely 
$1
,23
8). 
A lso 
on 
or 
about 
December 
30, 2025, 
VAN 
DYKE 
purchased 
approximat
ely  850 
add
itiona
l  shar
es 
of 
the 
market 
"Mad
uro 
out 
by 
... 
January 
3 1,  2026" 
at 
a 
volum
e-wei
ghted  ave
rage 
price 
of 
approximately 
$0.
10  per 
share, 
for 
a  tota
l  pur
chase 
pri
ce 
of 
approxim
ately 
85 
USDC.e 
(ap
proxima
tely $85). 
5 

c. 
On 
or 
about 
January 
I, 2026, 
VAN 
DYKE 
purchased 
approximately 
17,858 
''YES" 
shares 
of 
the 
market 
"W
ill 
the 
U.S. 
invade 
Venezuela 
by 
... 
January 
31
," 
approximately 
1,752 
"YES" 
shares 
of 
the 
market 
"T
rump 
in vokes 
War 
Powers 
against 
Venezuela 
by 
... 
January 
31," 
and 
approximately 
73,685 
"YES" 
shares 
of 
the 
market 
"Maduro 
out 
by 
... 
January 
31" 
at 
a volume
-weighted 
average 
price 
of 
approx
imat
ely 
$0.06, 
$0.06, 
and 
$0.07 
per 
share, 
respectively, 
for 
a total 
purchase 
price 
of 
approximately 
6,100 
USDC.e 
(approximately 
$6,100). 
d. 
On 
or 
about 
the 
morning 
of 
January 
2, 
2026, 
VAN 
DYKE 
purchased 
approximate
ly 3,618 
"YES" 
shares 
of 
the 
ma
rket 
"Tr
ump 
invokes 
War 
Powers 
a
ga
inst Venezuela 
by 
..
. January 
31," 
and 
purchased 
app
roximately 
90,347 
"YES
"  shares 
of 
the 
market 
"Maduro 
out 
by 
... 
Jan
uary 
3 1"  at a volume
-weighted 
average 
pric
e 
of 
approximately 
$0.04, 
and 
$0
.07 
per 
share
,  respective
l
y, 
for 
a  total 
pur
chas
e  price 
of 
approximately 
6,150 
USDC.c 
(approximatel
y 
$6
, 150). 
That 
evening, 
VAN 
DYKE 
purchased 
approximately 
82,42
1 "YES" 
shares 
of 
the market 
"Ma
duro 
out 
by 
... 
January 
31" 
at 
a vo
lum
e-weighted 
average 
price 
of 
approximately 
$0.07 
per 
share
, 
fo r  a  total 
purchase 
price 
of 
approximate
ly  6,000 
USDC.e 
(approximately 
$6,000). 
That 
evening, 
VAN 
DYKE 
also 
transferred 
add
itional 
funds 
into 
bis 
Polymarket 
account, 
which 
he 
used 
to 
purchase 
add
itional 
approximately 
564 
"YES" 
shar
es 
of 
the 
mar
ke
t 
"US 
fo
rces 
in 
Venezu
ela 
by 
January 
3 1, 
2026
" 
and 
an 
additional 
87,500 
''YES" 
share
s 
of 
the 
market 
"Mad
uro 
out 
by 
... 
January 
3 J" 
at 
a  volume-we
ighted 
avera
ge 
price 
of 
ap
proximately 
$0.07 
and 
$0.08 
per 
share
,  respectively, 
for 
a  total 
purchase 
pri
ce 
of 
approximate
ly  7,050 
USDC
.e  (approximate
ly 
$7,050). 
Approximately 
45 
min
utes 
later, 
VAN 
DYKE 
purchased 
approximately 
88
, 1
87 
"YES" 
share
s 
of 
the 
market 
"Maduro 
ou
t  by 
... 
January 
3 1" 
at 
a  volume-weighted 
average 
price 
of 
6 

app
roximate
ly 
$0.08 
per  share  for 
a 
total  pur
chase 
price 
of 
app
roxima
tely 
7,215 
USDC.e 
( approx
i
ma
tely $7,2
1
5). 
1
2. 
GANNON 
KEN 
VAN 
DYKE, 
the 
defe
ndant, 
was 
invo
lved 
in 
the 
p lannin
g 
and 
execution 
of 
Ope
ra
ti
on 
Absolute 
Reso
lve, 
and 
he 
possessed 
mate
rial 
nonp
ubli
c information 
about 
tha
t  operat
i
on 
at 
the 
tim
e 
of 
each 
and 
every 
lrade 
he 
p laced 
in 
Mad
uro-
and 
Ven
ezue
la-relate
d 
markets. 
VAN 
DYKE 
had 
rec
eived 
that 
information 
as 
part 
of 
his 
em
pl oymen
t, and 
und
er 
a dut
y 
of 
trus t and 
confidence 
to 
ma
int
ain 
the 
co
nfid
entiali
ty 
of 
such 
class
ifie
d information 
and 
to 
no
t u  se 
it 
fo
r 
per
so
nal 
matte
rs or gain. 
By 
mi
sa
ppropriatin
g and us
in
g that 
informatio
n to 
exec
ute 
trad
es, 
VAN 
DYKE 
breached 
bis  duty 
of 
trust  and 
confidenc
e  to 
the 
sourc
e 
of 
the 
in
forma
tion,  and 
violated 
specific 
commi
tm
ents VA
N 
DYKE 
had 
made 
to  the 
Unit
ed 
States 
regard
ing t
he  use 
of 
the  infonnati
on. 
The 
Uni
ted  Stat
es 
Announce
s 
Maduro
's 
Capt
ure  and 
VAN 
DYKE 
Cas
hes 
Out 
13. 
ln the 
predawn 
hours 
of 
January 
3, 
2026, 
U.S. 
specia
l forces 
apprehended 
Madur
o 
and 
his 
wife 
at 
a residence 
in  Caracas, 
Venezue
la. 
The 
Pre
sident 
of 
the 
Uni
ted  States 
annoW1ced 
the o
pera
ti
on 
in 
a soc
ial 
media 
po
st  on or about 
Janu
ary 
3, 
2026, 
at  app
roxima
tely 4:21 
AM 
EST. 
14
. 
On 
or abo
ut 
January 
3, 
2 026, 
at approx
im
ate
ly 5:45 
AM 
EST
-   1usl hour
s after 
the 
U.S. 
military 
appre
hended 
Maduro 
an
d transport
ed  him 
to 
the  USS 
lwo 
Jima
-
a  p
hotog
raph 
of 
GANNON 
KEN 
VAN 
DYKE
,  the 
defe
nd
ant, 
was 
taken, 
and 
sub
se
quently 
uploaded 
to 
VAN 
DYKE
's 
Goog
le  account. 
T hat phot
ogra
ph 
depict
s  VAN 
DYKE 
on  wha
t appear
s  to  be 
the 
dec
k 
of 
a 
sh
ip 
at  sea, 
at  sunri
se 
wearing 
V.S. 
mi
litary 
fa
tigues, 
an
d carry
ing 
a 
rifle, 
st
andin
g 
alongs
ide 
three 
o ther 
indivi
du
a ls wearin
g U.S. 
milit
ary 
fatigu
es
. 
1
5. 
Fo
ll
owin
g 
the 
President's 
public 
announcemen
t, 
Po
lymarket 
resolved 
seve
ral 
Madw
·o-  and 
Ve
nezu
ela-related 
contracts 
to 
"YES" 
at 
$1.00 
per  share, 
includ
in
g  t
he  markets 
7 

" Maduro 
ou
t by 
... 
January 
31, 2026," 
and 
"US 
fo
rces 
in 
Venezue
la by 
... 
January 
3 1, 2026." 
As 
a  resu
lt,  GANNON 
KEN 
VAN 
DYK
E, 
the 
defendant
, won 
his 
wagers 
on 
those 
contracts. 
On 
or 
abo
ut 
January 
3, 2026, 
VAN 
DYKE 
so
ld his positions 
fo
r a profi
t 
on 
the markets 
"Trump 
invokes 
War 
Powers 
against 
Venezue
la 
by 
... 
January 
3 1'' 
and 
" W.
ill 
th
e 
U.S. 
invade 
Venezue
la 
by 
..
. January 
31. '' 
Ult
im
ately, 
"Wi
ll 
the 
U.S. 
invade 
Venezue
la 
by 
... 
January 
31" 
resolved 
to 
"NO/' 
but 
VAN 
DYKE 
avoided 
losses 
on 
that 
market 
by 
se
ll
ing 
his posit
ion before 
it resolved. 
In 
total, 
YAN 
D YKE 
profited 
approximate
ly $409,88
1. 
VAN 
DYKE 
Attempted 
to 
Conceal 
Hi
s 
Un
lawfu
l 
Pr
oceeds 
and 
Co
ncea
l Acco
un
ts He Used 
to 
Make 
Bets 
16. 
Fo
ll
owing 
hi
s  s
uccessfu
l  trading 
relat
ing 
to 
Mad
uro
-  an
d 
Venezue
la-re
lated 
contrac
ts ,  GANNON 
KEN 
YAN 
DY
KE, 
the 
defendan
t, 
transferred 
and 
d isguised 
the 
proce
eds 
from 
hi s scheme. 
On 
or 
about 
Jan
uary 
3, 
2026
, he w
ith
drew 
funds, 
in
cl
uding 
the 
m
t1:
iority 
of 
bis 
unl
awfu
l pro
ceeds
, from 
bis 
Po
lymark
et  accoun
t  and 
sent 
app
r
ox
imat
e
ly 
437,859 
US
DC.e 
of
t be 
proceeds 
to 
a 
fo
reign 
cryp
tocu
rrency 
"v
ault
," 
which 
advertis
es 
that 
it 
ge
nera
tes 
int
erest  for 
depositors 
by 
le
nclin
g 
cryp
tocu
rrency 
and 
tan
gible asse
t
s to 
other
s.  On 
or 
abo
ut 
Jan
uary 
16, 
2026, 
VAN 
DY
KE 
then 
tran
sfe
rred 
approxi
m ate
ly 
444
,209 
USDC.e 
from 
the  cryp
toc
urre
n
cy 
va
ult 
account 
to his 
cryptoc
urr
ency 
exchange 
accou
nt. From 
there
, he 
wi 
thdrcw 
approximate
ly $4
44
,209 
from 
the  accoun
t  and 
dep
osited 
it 
into 
a  newly
-crea
ted  brokerage 
account. 
As 
of 
on 
or  abo
ut 
A pril 21, 
2026, 
th
at 
brokerage 
acco
un
t conta
i
ns 
a balance 
of 
approxima
tely $415,5
11
, rep
rese
nting 
procee
ds traceab
le to 
YAN 
DYKE
's 
Po
lymarket 
had
e
s. 
1
7. 
Short
ly 
after 
the  announc
eme
nt 
of 
Maduro' 
s capture, 
reports 
of 
unu
sual tradin
g in 
Mad
uro-
relat ed  cont
racts 
on 
Polymark
et  appeared 
in 
the  press 
and 
on 
socia
l media. 
GANNON 
KEN 
VAN 
DYKE, 
the 
defe
ndant
,  then 
t
ook 
steps 
to 
concea
l  hi s  identi
ty 
as 
the  trader 
in 
the 
Madur
o-
and 
Vene
zue
la
-r
elated 
marke
ts
. On 
or 
about 
Jan
uary 
6, 2026, 
fo
r 
exa
mpl
e,  VAN 
D YKE 
8 

asked 
Polymarket 
to delete 
his 
Po
lymarket 
account
, 
falsely 
claiming 
that 
he 
had 
lost 
acce
ss 
to 
the 
email 
address 
to 
which 
the 
account 
had 
been 
associated
. That 
same 
day
, VAN 
DYKE 
changed 
the 
emai
l 
registered 
to 
his  cryptocurre
ncy 
exc
hange 
acco
unt 
to 
an 
email 
address 
tha
l  was 
not 
subscri
bed to 
in 
his 
name
, which 
email 
address 
was 
created 
on 
or about 
Decembe
r 
14
., 
2025. 
Statutory 
Allegations 
I 
8. 
From 
at 
leas
t in 
or 
a bout 
December 
2025 
up 
to 
and 
including 
a t leas
t 
in 
or 
about 
January 
2026, 
in 
the 
Southern 
Distr
ict 
ofNew 
York 
and 
elsewhere, 
GANNON 
KEN 
VAN 
DYKE, 
the 
defe
ndant
, an 
emp
loyee 
and 
age
nt 
of 
a department 
and 
agency 
of 
the 
Fede
ral Government, 
who 
by 
virtue 
of 
his emp
loymen
t 
an~ 
position, 
acquired 
infonnation 
tha
t may 
affec
t and 
tend 
to 
affec
t 
the  pri
ce 
of 
a commodity 
in 
inter
state 
commerce, 
and 
for 
future 
del ivery, 
and 
a swap, 
and 
which 
informatio
n  had 
not 
disseminated 
by 
the  department 
and 
agency 
of 
the  Federa
l  Government 
holdin
g and 
creating 
the 
informa
tion 
or 
by 
Congress 
or 
by 
the 
judiciary 
in 
a manner 
w
hi
ch 
made 
it 
genera
lly  ava
il
able  to 
the  trading 
public
,  or 
disclosed 
in 
a  crimina
l,  civil
, 
or 
admin
istrat
ive 
hearing, 
or 
in 
a 
congress
ional, 
administrative, 
or  Government 
Acco
untabilil"y 
Office 
report, 
hearing, 
a udit
,  or  inve
stigati
on, 
wil
lfully  and 
knowingly
,  u
sed 
the  info
rmation 
in 
his 
personal 
capacity 
and 
for 
persona
l  gain 
to  e
nter 
into
,  and  offe
red 
to  enter 
int
o, 
a  co
ntract 
of 
sa
le 
of 
a 
commod
ity 
for 
future 
deli very 
(and 
option 
on 
such 
a con
tract)
; 
and 
an option 
(o
ther than 
an 
op
ti
on 
exec
uted 
or traded 
on 
a  nationa
l securities 
exchange 
registere
d pursuant 
to 
sect
i
on 
78f(a) 
of 
title 
15); 
and 
a  swap, 
to 
wit
, 
VAN 
DYKE
,  knowing 
that 
he 
had 
obta
ined 
material 
nonpub
lic 
Government 
in formation, 
used 
it 
to execute 
swap 
tran
sac
ti
ons in 
the 
form 
ofb
in
ary 
eve
nt 
contract
s 
for 
per
sona
l 
ga
in
. 
(T
itle 
7, 
United 
States 
Co
de, Section 
6c(a)(3), 
13(a)(5); 
and 
Title 
18
, United 
States 
Code, 
Section 
2.) 
9 

COUNT 
TWO 
(Theft 
of 
Nonpublic 
Government 
Information) 
The 
Grand 
Jur
y further 
charges: 
19. 
The 
allegation 
contai
ne
d  in 
parag
raph
s  l  through 
17 
of 
thi
s 
[ndi
ctment 
are 
hereb
y 
repe
ate
d,  realleged
, and 
incorporated 
by 
reference, 
as 
if 
fulJy 
set 
fo
rth 
berei 
n. 
20. 
F rom 
at 
lea
st  in 
or abo
ut 
December 
2025 
up 
to 
and 
includi
ng 
at 
least 
in 
or 
about 
January 
2026, 
in the Southern 
District 
of 
New 
York 
and 
elsewher
e,  GANNON 
KEN 
VAN 
DYKE, 
the defendant, 
sto
l
e, 
converte
d, and 
mi
sap
propriate
d, informat
i
on 
held 
and 
crea
ted 
by 
a departme
nt 
and 
agency 
of 
the Fede
ral  Government
,  which 
inf
ormatio
n ma
y affect 
and 
te
nd 
to a
ff
ect  the 
price 
of 
a comm
odity 
in 
int
erstate 
commerce, 
and 
for 
future 
delive
ry , 
and 
a swap
,  where 
VAN 
D YKE 
knew, 
and 
acted 
in 
reckless 
disregard 
of 
tbe 
fact, 
that 
such 
infor
m
a6o
n 
had 
not 
been 
disse
minat
ed 
by 
the 
de partment 
and 
agency 
o f the 
Fe
deral 
Governm
ent 
holding 
and 
creating 
the in
fo
r
ma
tion  or 
by 
Co
ngress 
or b
y the 
judic
iary 
in 
a mann
er which 
made 
it genera
ll
y ava
il
able to the 
tradin
g pub
lic, 
or 
disclosed 
in 
a cri
mi
nal
, civll, or 
administ
rative 
hearing, 
or 
in 
a con
gressio
nal, administrative, 
or 
Governme
nt 
Accountabi
li
ty 
Office 
repo
rt,  hearin
g, 
audi
t, 
or   invest
igation,   and 
used 
such 
infonnat
ion, and 
im parte
d such 
information 
with 
the 
int
ent 
to  assis
t  anoth
er  person, 
dir
ec
tly 
and 
indir
ec
tl
y,  to  use 
such  informa
tion 
to 
en
t
er 
into, 
and 
offer 
to  ente
r  into 
a  contract 
of 
sale 
of 
a 
co
mmodit
y  for 
future 
deliv
ery 
(and 
op
ti
o n on 
such a cont
ract); 
and 
an o
pti
on (oth er than 
an 
option 
executed 
or 
tr
aded 
on a national 
sec
urities 
excha
nge 
registe
red pur
suan
t  to  sec
tion 
78t1a) 
o
hitl
e 
15)
;  and 
a 
swap
, 
to 
\,vit
, 
YAN 
DYKE 
obtained 
mate
ri
al  nonpub
lic  Governme
nt 
informa
ti
on 

relevant 
to 
the  p
rice 
of 
swn
p 
contracts 
regarding 
miLitary 
ac tion 
in 
Venezue
la, 
and 
used 
it 
to 
exec
ute 
swap 
tran
sact
ion
s 
for 
personal 
gain. 
(Title 
7, 
Un
ited 
States 
Co
de, Section 
6c(a)(4)(C), 
l 3(a)(5); 
and 
Title 
18
, United 
State
s Co
de, 
Section 
2.) 
COUNT 
THREE 
(Commodities 
Fraud) 
The 
Grand 
Jury 
further 
charges: 
21. 
The 
allegatio
n contained 
in 
paragraphs 
1 thr
ough  17 
of 
this 
IncLictm
ent 
are 
hereby 
repeated, 
real
lege
d
1 
and 
in
corporated 
by 
re
fe rence, 
as 
if 
fully 
set 
forth 
her
ei
n. 
22. 
From 
at 
least 
in 
or 
abo
ut 
December 
2025 
up 
to  and 
including 
at 
least 
in 
or 
about 
January 
2026, 
in 
the 
So
uthern 
District 
ofNew 
Yo
rk 
and 
elsewhere, 
GAN'NON 
KEN 
VAN 
DYKE
, 
the 
defendant, 
willfully 
and 
knowingly
, 
di.reedy 
and 
indirectly, 
used 
and 
employed
, and 
attempted 
to 
use 
and 
emp
loy
,  in 
co
nn
ection 
with 
a  swap, 
a 
contract 
of 
sale 
of 
a  commod
ity 
in 
interstate 
commerce, 
and 
for 
future 
delivery 
on and 
s
ubj
ect t  o the rul
es 
of 
a regis
tered 
ent ity, 
a 
manipulative 
and 
dece
ptiv
e device and 
contrivance
, in 
contravention 
of 
Ti
tle  17, 
Code 
of 
Federa
l Regulations
, 
Sect
ion  180.1, 
b
y: 
(1)  using 
and 
employ
ing, 
and 
a
tt
empting 
to 
use 
and 
emp
loy) 
a  manipulative 
device, 
scheme, 
and 
artifice 
to 
defraud; 
(2) 
making
, 
and 
attempting 
to  make
, 
an 
untrue 
and 
misleading 
s
ta
tement 
of 
a mat
erial 
fact 
and 
omitt
ing 
to state 
a materia
l fact 
necessary 
in 
order 
to 
make 
the 
statements 
made 
not 
untrue 
and mislea
ding
; and 
(3) 
engaging, 
and 
attempting 
to 
engage 
in 
an 
act, 
pract
ice, 
and 
course 
of 
business 
which 
operates 
and 
wo
uld 
ope
rate 
as 
a fraud 
and 
deceit 
upon 
a 
person
, to 
wit, VAN 
DYKE
, 
know
ing that he had 
obtained 
mater
ial 
nonpublic 
inf
orma
ti
on 
in 
breach 
of 
a duty, 
used 
it 
to execute 
sw
ap 
tra
nsactio
ns for 
perso
na
l gain. 
(Title 7, 
Uni
ted 
States 
Co
de,  Sectio
ns 9( 1), 
13
(a)(5)
; T itle 
l 
7, 
Code 
of 
F ederal 
Regu
latio
ns, 
Sec
tfon 
180.1
; 
and 
Title 
18
, 
Un.i 
Led 
Stat
es 
Co
de, Section 
2.) 
11 

T
he 
Gra
nd 
Jury 
further 
char
ges: 
COUNT 
FOUR 
(Wire 
Fraud) 
23
. 
The 
allegatio
n conta
ined 
in 
paragrap
hs  1 thr
ough 
17 
of 
thi
s Indictment 
are 
hereby 
repeate
d, realleged
, and 
incorporated 
by reference, 
as 
if 
fully 
se
t forth 
her
ein . 
24. 
From 
at 
least 
in 
or 
abo
ut 
December 
20
25 
up 
to 
and 
includin
g 
at 
leas
t 
in 
or 
abo
ut 
Jan
ua
ry 
2026, 
in 
the 
So
uthem 
Di
strict 
of 
New 
Yor
k and 
e lsewhe
re, GANNON 
KEN 
VAN 
DYKE
, 
the 
defend
ant, knowin
gly 
ha
ving 
devised 
an
d int
ending 
to 
devise 
a schem
e and 
artific
e to 
defraud
, 
and 
fo
r 
obtaining 
mone
y and 
pro
perty 
by 
means 
of 
false 
and 
fraudulent 
pretenses, 
rep
rese
n
tat
ions
, 
and 
promises
,  transm
itted 
and 
cause
d to 
be 
transmitted 
by 
mean
s 
of 
wire. 
rad
io,  and 
television 
comm
uru
catio
n 
in 
int
ersta
te and 
fo
r
eig
n  commerce, 
writ
in
gs, 
signs, 
signals, 
pi
cture
s, and 
sound
s 
for 
the 
p urp
ose 
of 
exec
uting s
uch 
sc
he
me 
and 
artifice
, to 
wit
, VAN 
DYKE
, knowing 
that 
he had 
obtained 
mat
erial 
nonpublic 
infonn
ati on 
subjec
t   to 
a 
duty 
of 
confidentiality
,   and 
whic
h 
informat
i
on 
has 
pecuniary 
value, 
and  was 
in 
fact 
used 
fo
r 
VA
N 
DYKE
' s  pecuniary 
gain, 
VAN 
DYKE 
used 
such 
infonn
ati on 
to 
exec
ut
e  and cause 
others 
to exec
ute 
comm
odit
ies 
transact
i ons to 
obtai
n money 
in 
breac
h 
of 
his duties. 
(Titl
e 
18
, U
nit
ed 
States 
Co
de,  Secti ons 
13
43, 
and 
2.) 
COUNT 
FIVE 
(Engaging 
in 
a 
Monetary 
Transaction 
in 
Property 
Derived 
from 
Specified 
Unlawful 
Activity) 
The 
Grand 
Jury 
further 
charges: 
25. 
The 
allegation 
co
nt
ai
ned  in 
paragrap
hs  1 through 
17 
of 
thi
s  Indi
ctment 
are h ereby 
repeated, 
rea
llege
d, an
d i
ncorporate
d by 
re ferenc
e, as 
if 
fully 
set  fort
h h
erein, 
26
. 
On 
or 
abo
ut 
Januar
y 
22, 
2026, 
in 
th
e Southern 
D istr ict 
of 
New 
York 
and 
else
wh
e re, 
GANNON 
KEN 
VA
N 
DYK
E, 
the 
d
efe
ndant
,  within 
the Unit
ed 
S
tate
s,  knowing
ly  e
ngage
d  and 
12 

attempted 
to 
engage 
in a 
mone
t
ary 
tran
sac
tion
, as 
defi
ned 
in Title 
18, 
United 
States 
Code, 
Sect
ion 
1957(t)(l), 
in 
cr
im
ina
lly  derived 
property 
of 
a  val
ue 
greater 
than 
$10
,000 
that 
was 
derived 
from 
specified 
unlawfu
l activity, 
to 
wit
, VAN 
DYKE 
mad
e,  and 
directed 
others 
to 
make
, a wire 
transfer 
of 
approximately 
$300,000 
derived 
from 
the 
offense 
alleged 
in 
Cou
nt Four 
of 
thi
s Indictment. 
(T
itle 
18, 
United 
State
s Code
, Sections 
1957, 
and 
2.) 
FORFEITURE 
ALLEGATIONS 
27. 
As 
a  res ult 
of 
committing 
the  offense 
alleged 
in 
Co
unt 
Four 
of 
this 
Indictment
, 
GANNON 
KEN 
V
AN 
DYKE
, 
th
e  defendant
, shall 
forfe
it to 
the 
Un
ite
d  States, 
pursuant 
to 
Title 
18
, 
Unit
ed  States 
Code, 
Sectio
n 
98l(a)(
l )(C) 
and 
Title 
28
, United 
States 
Code, 
Section 
246
l(
c), 
any 
and 
a
ll 
property
, rea
l and 
per
sonal, that 
con
stitutes 
or 
is derived 
fr
om 
proceeds 
traceab
le to 
the 
commiss
ion 
of 
said 
offense
, includin
g but 
not 
limit
ed 
to a sum 
of money 
in 
United 
States 
curr
ency 
represe
ntin
g the 
amount 
of 
proceeds 
tracea
ble 
to the 
comm
ission 
of 
said 
offe
nse and 
the 
fo
llowing 
specifi
c property
: 
1. 
All 
funds 
held  in  Acco
unt 
No. 
U2396946
1 
at 
In
teract
ive  Broker
s 
held 
in 
the 
nam
e 
of'
'Ganno
n 
K 
Van 
Dyke." 
2. 
$50,066.36 
in 
UnHed 
States 
currency 
held 
on 
dep
osit  in 
Accoun
t 
No. 
108
29
1049 
at USAA 
Bank 
held 
in 
the name 
of 
etG
ANNON 
KEN 
VAN 
DYKE
." 
(1) thr
oug
h (2), 
collectively
, th e "S
pecifi
c Property.
" 
28. 
As 
a  result 
of 
commi
tting 
th
e  offen
se 
allege
d 
in 
Cou
nt 
Five 
of 
th is  Indi
ctment
, 
GANNON 
KEN 
VAN 
DYKE, 
t he de fendant
,  s  hall  forfe
it to 
the Uni
ted  States
, pur
suant 
to 
Titl
e 
18, 
United 
State
s Co
de, Section 
982(
a)( 
I), any a
nd 
all 
property
, rea
l an
d 
per
sona
l, involved 
in 
said 
offe
nse, 
or 
any 
prop
erty 
trac
eab
le to 
such p
roperty, 
includin
g but 
not  limit
ed t
o a sum 
of 
money 
in 
13 

United 
States 
currenc
y  representing 
the 
amo
unt 
of 
prop
erty 
involved 
in 
said 
offen
se 
and 
the 
Specific 
Property. 
Substitute 
Assets 
Provision 
29. 
[f 
any 
of 
the above-described 
forfeitab
le property, 
as 
a result 
of 
any 
act 
or 
omission 
of 
th
e defen
dan
t: 
a. 
cannot 
be 
located 
upon 
tbe 
exerc
i
se 
of 
due 
dili
gence; 
b. 
has 
been 
tran
sferred 
or so
ld 
to, 
or deposited 
with, 
a third 
per
son; 
c. 
has 
been 
p laced 
beyond 
the 
jurisdiction 
of 
the 
Co
urt; 
d. 
has 
been 
sub
stan
tially 
diminished 
in 
value; 
or 
e. 
has 
been c
omm ingled with 
other 
prop
erty 
which 
cannot 
be 
s ubdivided 
without 
diffi
culty; 
it 
is 
the intent 
of 
the 
United 
State
s, pursuant 
to Title 
2
1, 
United 
States 
Code, 
Section 
853(p) 
and 
Title 
28, 
United 
States 
Co
de, Section 
246l(c), 
to 
see
k forfei
ture 
of 
any 
other 
property 
of 
the 
defendant 
up 
to 
the 
value 
of 
the a
bov
e forfe
itable 
prop
erty. 
(Titl
e 
7, 
United 
States 
Co
d
e, 
Section 
2 156; 
Title 
18, 
United 
State
s Co
de, Sections 
98 
I, 982; 
Title 
21, 
United 
States 
Code, 
Section 
853
; and Titl
e 2
8, 
Unite
d 
States 
Co
de, 
Section 
2461.) 
United 
States 
Attorney 
14 

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA
v.
WILLIAM ANTONIO SOLIS,
a/k/a “Vegano,”
a/k/a “La Vega,”
Defendant.

ORIGINAL
INDICTMENT
26 Cr.
26 CRIM 149

COUNT ONE
(Murder While Engaged in a Narcotics Conspiracy)

The Grand Jury charges:

1. On or about June 21, 1993, in the Southern District of New York and elsewhere, WILLIAM ANTONIO SOLIS, a/k/a “Vegano,” a/k/a “La Vega,” the defendant, while engaging in an offense punishable under Title 21, United States Code, Section 841(b)(1)(A), namely, a conspiracy to distribute and possess with intent to distribute five kilograms and more of mixtures and substances containing a detectable amount of cocaine, intentionally killed, and counseled, commanded, induced, procured, and caused the intentional killing of Luis Guerrero, which resulted in such killing, and aided and abetted the same, to wit, SOLIS participated in the fatal shooting of Guerrero inside of 1386 Nelson Avenue in the Bronx, New York, during a drug-related robbery and kidnapping.

(Title 21, United States Code, Section 848(e)(1)(A); and Title 18, United States Code, Section 2.)

---

COUNT TWO
(Murder While Engaged in a Narcotics Conspiracy)

The Grand Jury further charges:

2. On or about June 21, 1993, in the Southern District of New York and elsewhere, WILLIAM ANTONIO SOLIS, a/k/a “Vegano,” a/k/a “La Vega,” the defendant, while engaging in an offense punishable under Title 21, United States Code, Section 841(b)(1)(A), namely, a conspiracy to distribute and possess with intent to distribute five kilograms and more of mixtures and substances containing a detectable amount of cocaine, intentionally killed, and counseled, commanded, induced, procured, and caused the intentional killing of Danis Sime, which resulted in such killing, and aided and abetted the same, to wit, SOLIS participated in the fatal shooting of Sime inside of 1386 Nelson Avenue in the Bronx, New York, during a drug-related robbery and kidnapping.

(Title 21, United States Code, Section 848(e)(1)(A); and Title 18, United States Code, Section 2.)

FOREFITUITION ALLEGATION

3. As a result of committing the offenses alleged in Counts One and Two of this Indictment, WILLIAM ANTONIO SOLIS, a/k/a “Vegano,” a/k/a “La Vega,” the defendant, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853, any and all property constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said offenses, and any and all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, said offenses, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of the offenses.

---

Substitute Asset Provision

4. If any of the above-described forfeitable property, as a result of any act or omission of the defendant:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third person;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853, and Title 28, United States Code, Section 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.

(Title 21, United States Code, Section 853 and Title 28, United States Code, Section 2461.)

FOR PERSON

JAY CLAYTON
United States Attorney