United States v. FEDERICO HERNANDEZ GAMBOA, Southern District of New York (Feb. 12, 2024) — Complaint

AUSA: AMANDA CAITLIN WEINGARTEN 
UNITED STATES OF AMERICA 
v. 
FEDERICO HERNANDEZ GAMBOA, 
Defendant. 
SEALED COMPLAINT 
V
iolations of 18 U.S.C. §§ 2, 1028A, 
1344, and 1349  
COUNTY OF OFFENSE: 
NEW YORK 
SOUTHERN DISTRICT OF NEW YORK, ss.: 
JARED EANNUCCI, being duly sworn, deposes and says that he is a Special Agent with 
the United States Attorney’s Office for the Southern District of New York, and charges as follows: 
COUNT ONE 
(Conspiracy to Commit Wire Fraud) 
1.From at least in or about August 2020, through at least in or about May 2023, in
the  Southern  District  of  New  York  and  elsewhere,  FEDERICO  HERNANDEZ  GAMBOA,  the  
defendant,  and  others  known  and  unknown,  willfully  and  knowingly  combined,  conspired, 
confederated, and agreed together and with each other to commit wire fraud, in violation of Title 
18, United States Code, Section 1343.  
2.It  was  a  part  and  an object  of  the  conspiracy  that  FEDERICO  HERNANDEZ
GAMBOA,  the  defendant,  and  others  known  and  unknown,  knowingly  having  devised  and  
intending  to  devise  a  scheme  and  artifice  to  defraud,  and  for  obtaining  money  and property  by  
means  of  false  and  fraudulent  pretenses,  representations,  and  promises,  would  and  did  transmit  
and cause to be transmitted by means of wire, radio, and television communication in interstate or 
foreign commerce, writings, signs, signals, pictures, and sounds for the purpose of executing such 
scheme and artifice, in violation of Title 18, United States Code, Section 1343, to wit, GAMBOA 
agreed  to  make  and  cause  to  be  made  false  statements  to  victims   about  fictitious  sweepstakes  
lottery winnings to induce the victims to send funds to GAMBOA and others known and unknown, 
and caused others to send and receive, emails and other electronic communications, to and from 
the Southern District of New York and elsewhere, in furtherance of that scheme.  
(Title 18, United States Code, Section 1349.) 
COUNT TWO 
(Conspiracy to Commit Bank Fraud) 
3.From at least in or about October 2020, through at least in or about September 2022,
in the Southern District of New York and elsewhere, FEDERICO HERNANDEZ GAMBOA, the 
defendant,  and  others  known  and  unknown,  willfully  and  knowingly  combined,  conspired,  
2
4 MAG 612

2 
confederated, and agreed together and with each other to commit bank fraud, in violation of Title 
18, United States Code, Section 1344. 
4. It  was  a  part  and  an  object  of  the  conspiracy  that  FEDERICO  HERNANDEZ  
GAMBOA,  the  defendant,  and  others  known  and  unknown,  knowingly  would  and  did  execute,  
and  attempt  to  execute,  a  scheme  and  artifice  to  defraud  a  financial  institution,  as  that  term  is  
defined in Title 18, United States Code, Section 20, and to obtain moneys, funds, credits, assets, 
securities,  and  other  property  owned  by,  and  under  the  custody  and  control  of,  such  a  financial  
institution, by means of false and fraudulent pretenses, representations, and promises, in violation 
of Title 18, United States Code, Section 1344, to wit, GAMBOA agreed to make and cause to be 
made false statements to financial institutions, including by submitting and aiding and abetting the 
submission of forged and altered documents, in order to obtain funds under the custody and control 
of those financial institutions. 
(Title 18, United States Code, Section 1349.) 
COUNT THREE 
(Bank Fraud) 
 
5. From at least in or about October 2020, through at least in or about September 2022, 
in the Southern District of New York and elsewhere, FEDERICO HERNANDEZ GAMBOA, the 
defendant,  knowingly  executed,  and  attempted  to  execute, a  scheme  and  artifice  to  defraud  a 
financial  institution, as  that  term  is  defined  in  Title  18,  United  States  Code,  Section  20,  and  to  
obtain  moneys,  funds,  credits,  assets,  securities,  and  other  property  owned  by,  and  under  the  
custody  and  control  of,  such  a financial  institution,  by  means  of  false  and  fraudulent  pretenses,  
representations, and promises, to wit, GAMBOA engaged in a scheme to make false statements to 
financial  institutions,  including  by  submitting and  aiding and  abetting the  submission  of  forged  
and altered documents, in order to obtain funds under the custody and control of those financial 
institutions.  
(Title 18, United States Code, Sections 1344 and 2.) 
 
COUNT FOUR 
(Aggravated Identity Theft) 
 
6. From at least in or about August 2021, through at least in or about May 2023, in 
the  Southern  District  of  New  York  and  elsewhere,  FEDERICO  HERNANDEZ  GAMBOA,  the  
defendant,  knowingly  transferred,  possessed,  and  used,  without  lawful  authority,  a  means  of  
identification of another person, during and in relation to a felony violation enumerated in Title 
18, United States Code, Section 1028A(c), to wit, GAMBOA possessed and used, and aided and 
abetted  the  possession  and  use  of  the  names  and  personally  identifiable  information  of  other  
persons during and in relation to the bank and wire fraud violations charged in Counts One, Two, 
and Three of this Complaint.  
(Title 18, United States Code, Sections 1028A(a)(1), 1028A(b), and 2.) 
 
 The bases for my knowledge and for the foregoing charges are, in part, as follows: 

3 
7. I  am  a  Special  Agent  with  the  United  States  Attorney’s  Office  for  the  Southern  
District of New York.   I have been personally involved in the investigation of this matter.  This 
affidavit  is  based  upon  my  investigation,  my  conversations  with  law  enforcement  agents  and  
others, and my examination of reports and records.  Because this affidavit is being submitted for 
the  limited  purpose  of  establishing  probable  cause,  it  does  not  include  all  the  facts  that  I  have  
learned during the course of my investigation.  Where the contents of documents and the actions, 
statements, and conversations of others are reported herein, they are reported in substance and in 
part, except where otherwise indicated.  
Overview of the Sweepstakes Lottery Fraud Scheme 
8. As   set   forth   below,   there   is   probable   cause   to   believe   that   FEDERICO 
HERNANDEZ GAMBOA, the defendant, participated in a conspiracy to induce elderly victims 
to  send  wire  transfers  to  bank  accounts  that  were  purportedly  controlled  by  operators  of  a 
sweepstakes  lottery  (the  “Sweepstakes  Lottery”),  but were in fact controlled  by  GAMBOA  and 
other co-conspirators.  In connection with the Sweepstakes Lottery scheme (the “Fraud Scheme”), 
four victims (“Victims 1-4”) collectively sent approximately $4.3 million in fraud proceeds to bank 
accounts  that  were  controlled  by  GAMBOA  or  GAMBOA’s  co-conspirators,  approximately 
$664,000 of which were sent directly to bank accounts that were controlled by GAMBOA.   
9. As  part  of  the  Fraud   Scheme, FEDERICO   HERNANDEZ   GAMBOA,  the 
defendant, and others, induced at least four victims to send wire transfers to “FABUCredit Corp.,” 
a  company  for  which  GAMBOA is  the  owner,  president,  manager,  and  chief  operating officer.  
GAMBOA controls  the  bank  accounts  associated  with  FABUCredit  Corp.    FABUCredit  Corp.  
once maintained a website that reported that it was a luxury jewelry company and subsequently 
claimed to be a vendor for healthcare services.  Currently, FABUCredit Corp. maintains no online 
presence and does not appear to engage in any legitimate business dealings.      
Victim-1 
10. As set forth below, from in or about August 2021, up to and including in or about 
September 2022, Victim-1, who is 67 years old, was induced to send approximately $465,000 to 
bank   accounts purportedly   controlled   by   operators   of   the   Sweepstakes   Lottery,   at   least   
approximately $265,000 of which Victim-1 sent to FABUCredit Corp. bank accounts   that were 
controlled by FEDERICO HERNANDEZ GAMBOA, the defendant.  
11. Based  on  my participation  in  at  least  five  interviews   of  Victim-1 that  took  place 
from on or about November 20, 2022, through on or about October 12, 2023, my review of records 
and information provided by Victim-1, as well as my review of law enforcement records, I have 
learned the following: 
a. In or about August 2021, Victim-1 received a phone call from an individual 
who  identified  herself  as  an  employee  of  “National  Awards  &  Promotions”  (the  “NAP 
Impersonator”).      The   NAP   Impersonator   informed   Victim-1   that   Victim-1 had   won   an   
approximately $750,000 second-place prize in the Sweepstakes Lottery.  The NAP Impersonator 
subsequently  informed  Victim-1  that  the  first-place prize  winner  defaulted,  and  that  Victim-1 

4 
would also receive the first-place prize of approximately $1,200,000 for a total of approximately 
$1,950,000. 
b. A short time later, Victim-1 received a phone call from an individual who 
identified  himself  as  an  employee  of  the  United  States  Department  of  the  Treasury  and  United  
States Department of Commerce (the “Department of Commerce Impersonator”).  The Department 
of Commerce Impersonator informed Victim-1 that he was tasked with organizing the paperwork 
related to Victim-1’s sweepstakes winnings.  
c. On or about March 22, 2022, the Department of Commerce Impersonator 
emailed Victim-1 informing Victim-1 that Victim-1   needed to wire approximately $7,650 to the 
United States Department of Commerce for “identification bond and transportation insurance fees” 
associated with Victim-1’s sweepstakes winnings.  The Department of Commerce Impersonator 
provided  Victim-1  with  the  account  details  associated  with  a  particular  bank  account  (“Bank  
Account-1”).  
d. Later  that  same  day,  on  or  about  March  22,  2022,  Victim-1   followed  the  
Department of Commerce Impersonator’s directions and initiated a wire transfer in the amount of 
approximately $7,650 to Bank Account-1. 
e. Based  on  my  review  of  bank  records,  on  or  about  March  23,  2022, 
approximately  $4,455—over  half  of  the  money  that  Victim-1  wired  to  Bank  Account-1—was 
wired from Bank Account-1 to a bank account in Costa Rica with a false wire memorandum that 
read “Invoice payment for a physical good purchased.” 
f. From in or about March 29, 2022, through in or about May 9, 2022, Victim-
1  made  three  additional  wire  transfers  to  Bank  Account-1,  totaling  approximately  $124,519.47.  
Each  of  these  wire  transfers  were  made  at  the  direction  of  the  Department  of  Commerce 
Impersonator, who told Victim-1 that the payments were necessary fees associated with Victim-
1’s sweepstakes winnings.  
g. Immediately  after  Victim-1  wired  to  Bank Account-1  each  of  the  three  
above mentioned wire transfers, see supra ¶ 11(f),  a portion of that money was wired from Bank 
Account-1 to a bank account in Costa Rica.  The memoranda on the wires falsely represented that 
the wire transfers were for “Invoice payment for a physical good purchased” or “Office Expenses.”  
h. In or about July 2022, Victim-1 received an email (the “July 2022 Email”) 
from  an  individual  who  identified  himself  as  the  Deputy  Director  of  the  Financial  Crimes  
Enforcement Network (the “FinCEN Impersonator”).   
i. The July 2022 Email included two attachments (“Attachment 1” and 
“Attachment 2”): (i) Attachment 1 was a fraudulent invoice in the amount of $265,785 for taxes 
associated  with  Victim-1’s  sweepstakes  winnings  with  “FABUCredit  Corp[.]” written on  the  
letterhead, and (ii) Attachment 2 was a FABUCredit Corp. “Account Statement” detailing the four 
payments  that  Victim-1  made  to  Bank  Account-1  along  with  a  pending  payment  to  be  made  as  
detailed  in  the  fraudulent  invoice  in  Attachment  1.    Attachment  2  listed  “Accurate  Finance  
Group[;] a Division of FABUCredit Corp[.]” on the letterhead.   

5 
ii.In the July 2022 Email, the FinCEN Impersonator provided Victim-
1 with the banking information associated with FABUCredit Corp. (“FABUCredit Bank Account-
1”) at a particular bank, (“Bank-1”),
1
 and directed Victim-1 to wire the pending $265,785 payment 
to FABUCredit Bank Account-1.  
i.On or about July 13, 2022, Victim-1 followed the FinCEN Impersonator’s
instructions  and  initiated  a  wire  transfer for  approximately  $265,785  to  FABUCredit  Corp.  at  
FABUCredit Bank  Account-1.    For  the  reasons  set  forth  below,  I  believe  that  FEDERICO 
HERNANDEZ  GAMBOA,  the  defendant,  used  bank  accounts  in  the  name  of  FABUCredit 
Corp.—including FABUCredit Bank Account-1—in furtherance of the Fraud Scheme: 
i.On  or  about  March  10,  2023, a  Magistrate  Judge  sitting  in  this
District authorized a search warrant (the “Warrant”) for the iCloud account used by GAMBOA 
(“GAMBOA’s iCloud Account”).
2
    
ii.Based  on  my  review  of  data  obtained  pursuant  to  the  Warrant,  I
know that GAMBOA’s iCloud Account contained spreadsheets showing a breakdown of Victim-
1’s $265,785 wire transfer, including the transfer of some of those funds into accounts for other 
entities that are owned by GAMBOA.  As noted above, Victim-1 sent the $265,785 wire transfer 
to a FABUCredit Corp. account at FABUCredit Bank Account-1.  
iii.Based on my review of records received from Bank-1, and publicly
available  information  from  the  Florida  Department  of  State,  I  know  that  the  account  opening  
documents  associated  with  FABUCredit Bank  Account-1 list GAMBOA’s  name,  telephone  
number, email address, and mailing address.   
iv.Based  on  my  review  of  publicly  available  Florida  state  records,  I
know that GAMBOA is listed as the president of FABUCredit Corp. 
v.Based  on  my  review  of  data  obtained  pursuant  to  the  Warrant,  I
know  that  GAMBOA’s  iCloud  Account  contained a  photograph  of  a  check  made  out  to  
FABUCredit Corp.
j.Also on or about July 13, 2022, three wire transfers totaling approximately
$250,000 were sent from FABUCredit Corp. to three separate bank accounts in Costa Rica. 
k.In  or  about  September  2022,  Victim-1  received  a  phone  call  from  an
individual  who  identified  himself  as  the  Chief  of  the  Criminal  Division  of  the  United  States  
Attorney’s Office for the Southern District of New York (the “SDNY Impersonator”).  The SDNY 
1
 From my review of publicly available materials, as well as my training and experience, I know 
that, at all relevant times, the deposits of Banks 1-5, discussed herein, were insured by the Federal 
Deposit Insurance Corporation (“FDIC”). 
2
  The  phone  number  associated  with  FABUCredit Bank  Accounts  1-3, discussed  herein,  is  the  
same phone number associated with GAMBOA’s iCloud Account, which is subscribed to in the 
name “Federico Hernandez.”  Moreover, the address associated with GAMBOA’s iCloud Account 
is the same address listed in Florida state records for FABUCredit Corp.  

6 
Impersonator  told  Victim-1  that  he  was  investigating  the  Sweepstakes  Lottery  and  informed  
Victim-1 that there were outstanding taxes associated with Victim-1’s winnings that needed to be 
paid immediately. 
l. On or about September 29, 2022, Victim-1 received an email in which the 
SDNY Impersonator provided Victim-1 with the account details associated with a particular bank 
account (“Bank Account-2”), where the pending payment in the amount of $68,931.16 should be 
sent.  
m. On   or   about   September   29,   2022,   Victim-1   followed the SDNY 
Impersonator’s instructions and initiated a wire for $68,931.16 to Bank Account-2. 
n. That same day, three wire transfers totaling $63,950 were sent from Bank 
Account-2 to three separate bank accounts in Costa Rica. 
o. On  or  about  November  17,  2022,  Victim-1  received  an  email  from  the  
FinCEN Impersonator requesting an additional $92,355 for taxes and fees associated with Victim-
1’s sweepstakes winnings.  Attached to the email was an account statement showing Victim-1’s 
prior wire transfers to Bank Account-1 and FABUCredit Bank Account-1.  The letterhead on the 
invoice read, “FABUCredit Corp[.;] Accurate Finance Group[;] a division of Raddhaus LLC.”  In 
the  email  to  Victim-1,  the  FinCEN  Impersonator  provided  Victim-1  with  the  account  details  
associated with a particular bank account (“Bank Account-3”), where the pending payment should 
be sent.  Victim-1 did not make the requested payment. 
p. On  or  about  January  17,  2023,  Victim-1  received  an  email  from  the  
Department of Commerce Impersonator requesting an additional $25,598.63 for taxes associated 
with Victim-1’s sweepstakes winnings.  In the email to Victim-1, the Department of Commerce 
Impersonator provided Victim-1 with the account details associated with a particular bank account 
(“Bank Account-4”), where the pending payment should be sent.  The Department of Commerce 
Impersonator also provided Victim-1   a copy of a forged Department of Commerce identification 
card,  which  misspelled  the  words  “Washington”  and  “Financial.”    Victim-1  did  not  make  the  
requested payment.  
q. On  or  about  February  13,  2023,  Victim-1  received  a  phone  call  from  an  
individual who identified himself as the “Lead Attorney/Special Agent” with the “United States 
Attorney’s Office –   Western District of Virginia and Texas” (the “WDVA/WDTX Impersonator”).  
The WDVA/WDTX Impersonator  informed  Victim-1  that  the SDNY Impersonator had  turned  
over  Victim-1’s  case  to  him.    Also  on  or  about  February  13,  2023,  Victim-1  received  an  email  
from the WDVA/WDTX Impersonator which contained the United States Department of Justice 
seal.  

7 
Victim-2 
12. As set forth below, from in or about August 2022, up to and including in or about 
September 2022, Victim-2, who is 72 years old, was induced to send approximately $73,800 to 
bank accounts purportedly controlled by operators of the Sweepstakes Lottery, nearly all of which 
Victim-2  sent  to  FABUCredit  Corp.  bank  accounts  that  were  controlled  by  FEDERICO 
HERNANDEZ GAMBOA, the defendant.  
13. Based on my participation in at least three interviews   of Victim-2 that took place 
from on or about November 10, 2022, through on or about August 28, 2023, my review of records 
and information provided by Victim-2, as well as my review of law enforcement records, I have 
learned the following: 
a. In or about August or September 2022, Victim-2 received a phone call from 
an individual who identified herself as an employee of the “Consumer Protection Agency,” (the 
“CPA Impersonator”), and an individual who identified herself as an employee of the “Give-A-
Way Sweepstakes” (the “GAW Sweepstakes Impersonator”).  During the phone call, the CPA and 
GAW  Sweepstakes  Impersonators  informed  Victim-2  that  Victim-2 won  an  approximately  
$750,000  prize  in  the  Sweepstakes  Lottery.    The  CPA  and  GAW  Sweepstakes  Impersonators 
instructed  Victim-2  to  mail  a  check  for  approximately  $1,800  to  a  particular  name  and  mailing  
address  in  Texas  in  order  to  have  a  federal  bonded  trustee  issue  an  insurance  policy  for  the  
transaction.  
b. On  or  about  September  1,  2022,  Victim-2  followed  the  instructions  and  
mailed  a  check  in  the  amount  of  approximately  $1,800  to  the  address  that  the  CPA  and  GAW  
Sweepstakes Impersonators had provided. 
c. A short time later, Victim-2 received a phone call from an individual who 
identified himself as an employee of a particular bank (“Bank-2”), (the “Bank-2 Impersonator”).  
The Bank-2 Impersonator informed Victim-2 that Victim-2 needed to wire $28,000 to cover the 
“State  Entry  Fee”   for  the  “State  of  Nevada  Gaming  Commission.”    The  Bank-2  Impersonator 
provided Victim-2 with account details for FABUCredit Bank Account-1, the banking information 
associated  with  FABUCredit  Corp.    However,  when  Victim-2  attempted  to  wire  the  money  to  
FABUCredit Bank  Account-1,  bank  personnel  from  Bank-1  rejected  the  transaction.    Bank  
personnel told Victim-2 that the transaction was rejected due to suspicious activity in FABUCredit 
Bank  Account-1,  namely,  the  high  volume  of  money  moving  in  and  out  of  FABUCredit Bank 
Account-1.  Victim-2 relayed that information to the Bank-2 Impersonator, who then instructed 
Victim-2  to  mail  a  check  to  FABUCredit  Corp.  at  its  business  address  in Miami,  Florida (the 
“Florida Address”).  
d. On  or  about  September  7,  2022,  Victim-2 complied  with  the  instructions  
and mailed a check to FABUCredit Corp. for approximately $28,000 to the Florida Address.  This 
check was ultimately deposited into a bank account for FABUCredit Corp. (“FABUCredit Bank 
Account-2”) at a particular bank, (“Bank-3 ”). 
e. Based  on  my  review  of  records  provided  by  Bank-3,  I  know  that  the 
following day, on or about September 8, 2022, approximately $28,000, plus an additional $2,000, 

8 
was transferred out of FABUCredit Bank Account-2   into another bank account, and then into a 
cryptocurrency wallet.  
i. Based  on  my  review  of  data  obtained  pursuant  to  the  Warrant,  I  
know that GAMBOA’s iCloud Account contained an email dated October 29, 2022 from Bank-3 
that was addressed   to   FEDERICO   HERNANDEZ   GAMBOA, the   defendant, regarding 
FABUCredit Bank Account-2. 
f. Shortly  after  Victim-2  mailed  a  check  for  approximately  $28,000  to  
FABUCredit  Corp. at  the  Florida  Address,  the  GAW  Sweepstakes  and Bank-2    Impersonators 
contacted Victim-2 and instructed Victim-2   to mail another check for approximately $44,000 to 
FABUCredit Corp. at the Florida Address for additional fees.  
g. On  or  about  September  16,  2022,  Victim-2  mailed  a  check  made  out  to  
FABUCredit  Corp.  for  approximately  $44,000  to  the  Florida  Address.    Based  on  my  review  of  
data  obtained  pursuant  to  the  Warrant,  I  know  that  GAMBOA’s  iCloud  Account  contained  a 
photograph of this check. 
h. Based  on  my  interviews  of  Victim-2,  I  know  that  shortly  after  Victim-2 
mailed a check for approximately $44,000, Victim-2 began to suspect that Victim-2   was a victim 
of  fraud  and  contacted Victim-2’s  bank  to  stop  the  payment.    Personnel  from  Victim-2’s  bank  
informed  Victim-2  that  personnel  from  Bank-1  claimed  that  a  contract  was  submitted  between 
Victim-2 and FABUCredit Corp. to substantiate Victim-2’s $44,000 check to FABUCredit Corp. 
that was to be deposited into FABUCredit Bank Account-1.  Victim-2 informed me that Victim-2 
never  signed  any  type  of  contract  with  FABUCredit  Corp.    As  set  forth  below,  it  appears  that  
GAMBOA submitted or assisted in the submission of this fraudulent contract to Bank-1: 
i. Based  on  my  review  of  data  obtained  pursuant  to  the  Warrant,  I 
know that GAMBOA’s iCloud Account contained a photograph of the online banking profile for 
FABUCredit Bank Account-1 reflecting a $44,000 hold in or about September 2022.   
ii. GAMBOA’s  iCloud  Account  also  contained  a  purported  “Loan  
Agreement” between Victim-2 and FABUCredit Corp. dated April 15, 2022 (“Loan Agreement-
1”), which, for the reasons noted below, I believe to be fraudulent.  The notary public stamp on 
Loan Agreement-1 is  from Florida and dated May 22, 2018—approximately four years prior to 
the date of Loan Agreement-1.  The notary public stamp also appears to be identical to the May 
22,  2018  notary  public  stamp on a  Power  of  Attorney  document,   possessed  by  GAMBOA’s 
lawyers, between FABUCredit Corp. and another victim (“Victim-4”), discussed below, see infra 
¶ 17(e).  Based on my review of travel records for GAMBOA, I know that GAMBOA was not in 
the United States on or about April 15, 2022, or on or about May 22, 2018 (i.e., on the dates that 
these two agreements were purportedly executed).    
1. Loan  Agreement-1 purports  to  contain the  initials  and  
signature  of  Victim-2.    However,  when  shown  Loan  Agreement-1,  Victim-2  confirmed  that  
Victim-2 had never seen Loan Agreement-1 before and never signed or initialed it.  
 

9 
2. Based  on  my  review  of  documents  provided  by  Bank-1,  I  
know that Bank-1 obtained Loan Agreement-1 from members of the Fraud  Scheme, which was 
submitted to Bank-1 to substantiate the $44,000 check deposit from Victim-2.  
 
i. Based on my review of records provided by Bank-1, I know that on or about 
September 20, 2022, Victim-2’s check in the approximate amount of $44,000 was deposited into 
FABUCredit Bank Account-1 at Bank-1, and that on or about September 23, 2022, approximately 
$43,000 was transferred out of FABUCredit Bank Account-1 into another bank account, and then 
into a cryptocurrency wallet.  
i. Based  on  my  review  of  data  obtained  pursuant  to  the  Warrant,  I 
know that GAMBOA’s iCloud Account contained a photograph of Victim-2’s $44,000 check to 
FABUCredit Corp., and a photograph of a deposit ticket from FABUCredit Bank Account-1 dated 
September  22,  2022, in  the  amount  of  $44,000.    GAMBOA’s  iCloud  Account  also contained  a 
contacts list that includes Victim-2’s name and a phone number that is linked to Victim-2 based 
on publicly available information but which Victim-2 confirmed has never been associated with 
Victim-2. 
Victim-3 
14. As set forth below, from in  or about July 2022, up to and including in or about May 
2023,  Victim-3,  who is 66 years old,  was  induced  to  send  approximately  $3,600,000 to  bank  
accounts purportedly controlled by operators of the Sweepstakes Lottery, at least approximately 
$77,600 of  which  Victim-3  sent  to  FABUCredit  Corp.  bank  accounts  that  were controlled  by  
FEDERICO HERNANDEZ GAMBOA, the defendant.  
15. Based  on  my participation  in  at  least  two  interviews   of  Victim-3 that  took  place  
from on or about June 30, 2023, through on or about August 28, 2023, my review of records and 
information provided by Victim-3, as well as my review of law enforcement records, I have learned 
the following:  
a. In  or  about  July  2022,  Victim-3  received  a  phone  call  from  the  GAW 
Sweepstakes  Impersonator  who  informed  Victim-3  that  Victim-3  had won  an  approximately  
$8,000,000 prize in the Sweepstakes Lottery.   
b. From in or about July 2022, through in or about December 2022, the GAW 
Sweepstakes  Impersonator  and  other  individuals  that  purported  to  work  for  the  Sweepstakes  
Lottery,  induced  Victim-3  to  send wires  totaling  approximately  $3,600,000  for  purported  taxes  
and fees associated with Victim-3’s lottery winnings.   
c. For example, on or about July 15, 2021 and July 21, 2021, Victim-3 sent 
two  wire  transfers  totalling  approximately  $77,600  to  FABUCredit Bank  Account-2,  the  bank 
account  for  FABUCredit  Corp.  at  Bank-3.    Based  on  my  participation  in  this  investigation,  my 
review of publicly available documents, and my review of documents from Bank-3, I know that 
both  wire  transfers  were  interstate  wire  transfers  and  passed  through  a  bank  with  an  address  in  
New York, New York.  

10 
d. In   or   about   May   2023,   at   the   direction   of the GAW   Sweepstakes 
Impersonator, Victim-3 emailed a copy of Victim-3’s driver’s license to an email address provided 
by the GAW Sweepstakes Impersonator.   
i. Based  on  my  review  of  data  obtained  pursuant  to  the  Warrant,  I 
know that GAMBOA’s iCloud Account contained at least four photographs of driver’s licenses 
that  contain  Victim-3’s  personal  identifying  information,  but  that  contain  photographs  of  four  
different individuals, none of which depict Victim-3.  GAMBOA’s iCloud Account also contained 
photographs of  a  U.S.  passport  and Massachusetts identification  card  that  contain  Victim-3’s 
photograph and personal identifying information. 
ii. GAMBOA’s  iCloud  Account  also  contained  screenshots  of  a  text 
message conversation  that  included wire  transfer  information  for  one  of  the  wire  transfers  that  
Victim-3 sent.   
iii. GAMBOA’s iCloud Account also contained a document depicting 
a wire transfer that Victim-3 sent to a co-conspirator in the Fraud Scheme.  The document depicts 
Victim-3’s outgoing wire transfer into a particular bank (“Bank-4”). 
Victim-4  
 
16. As set forth below, from in or about October 2020, up to and including in or about 
November 2021, Victim-4, who passed away on or about August 19, 2022 at the age of 102, was 
induced to send approximately $250,000 to FABUCredit Corp. bank accounts that were controlled 
by FEDERICO HERNANDEZ GAMBOA, the defendant.  
17. Based on my participation in at least three interviews of a relative of Victim-4 (the 
“Nephew”) that took place from on or about June 29, 2023, through on or about October 13, 2023, 
my  review  of  records  and  information  provided  by  the  Nephew,  as  well  as  my  review  of  law  
enforcement records, I have learned the following:  
a. In  or  about  the  spring  or  summer  of  2020,  Victim-4 was  contacted  by  an  
individual who identified himself as an employee of the United States Department of the Treasury 
(the “Department of the Treasury Impersonator”).  The Department of the Treasury Impersonator 
told Victim-4 that Victim-4 won approximately $11,000,000 from the Sweepstakes Lottery and 
was entitled to an additional $2,700,000 from “State Bridge Insurance.”     The Department of the 
Treasury Impersonator sent Victim-4 a document that purported to be a contract in which Victim-
4  was  to  receive  $11,000,000  from  the  Sweepstakes  Lottery  and  $2,700,000  from  State  Bridge  
Insurance, in exchange for paying approximately $20,000 for an “indemnity bond” for finalization 
of payment proceeds from the Sweepstakes Lottery.  Thereafter, at the direction of the Department 
of the  Treasury  Impersonator, Victim-4  sent  a  cashier’s  check dated  August  14,  2020,  in  the  
amount of $250,000 to a FABUCredit Corp. bank account, (“FABUCredit Bank Account-3”) at a 
particular bank (“Bank-5 ”).   
b. On  or  about  August  15,  2020,  Victim-4’s  check  was  deposited  into 
FABUCredit Bank  Account-3 at  Bank-5.   By  on  or  about  August  26,  2020,  the  money  was  
withdrawn via seven separate wire transfers. 

11 
c. In or about the fall of 2021, the real and legitimate United States Department 
of  the  Treasury  opened  an   investigation  into  the  Fraud  Scheme and  contacted  Victim-4.   On  or  
about November 19, 2021, Victim-4 emailed a Special Agent with the Department of the Treasury 
and  informed  him  that  the  Department  of  the Treasury  Impersonator  asked  Victim-4    to  loan  
approximately $250,000 to FABUCredit Corp. for “expansion purposes.”   
d. Based on my review of data obtained pursuant to the Warrant, I know that 
GAMBOA’s iCloud Account contained a photograph of a cashier’s check dated August 14, 2020, 
from  Victim-4  in  the  amount  of  approximately  $250,000  made  out  to  FABUCredit  Corp.    
GAMBOA’s  iCloud  Account  also contained  a  loan  agreement  dated  June  2,  2021,  between 
FABUCredit  Corp.  and  Victim-4    for  a  loan  in  the  amount  of  approximately  $250,000 (“Loan 
Agreement-2”).   
i. On  or  about  October  13,  2023,  when I  showed  the  Nephew  Loan 
Agreement-2, the Nephew informed me that Loan Agreement-2 did not look familiar to him.   
e. Based on my review of documents I obtained from the Nephew, I know that 
on or about January 16, 2021, the Nephew sent the then-lawyers of FEDERICO HERNANDEZ 
GAMBOA, the defendant, a legitimate Power of Attorney document that Victim-4 signed on or 
about July 31, 2017.  The notary stamp on the Power of Attorney document is dated May 22, 2018 
and  is  identical  to  the  notary  stamp  on  Loan  Agreement-1,  which  is  dated April  15,  2022—
approximately four years after the date of the notary stamp.  
f. Based  on  my  interviews  of  the  Nephew,  I  know  that  in  or  about October 
2020, Victim-4 and the Nephew informed Victim-4’s bank that the $250,000 cashier’s check was 
sent  to  FABUCredit  Corp.  under  fraudulent  pretenses.    As  a  result,  Bank-5  froze  FABUCredit 
Bank Account-3.  
g. Based on my review of data obtained pursuant to the Warrant, I know that 
GAMBOA’s iCloud Account contained emails between GAMBOA and bank personnel at Bank-
5    dated  October  26,  2020, in  which  GAMBOA describes  Victim-4    as  an  investor  that  he  met  
through his attorneys.    
  

12 
WHEREFORE, the deponent respectfully requests that a warrant be issued for the arrest of 
FEDERICO HERNANDEZ GAMBOA, the defendant, and that he be arrested, and imprisoned or 
bailed, as the case may be. 
___________________________ 
J
ARED EANNUCCI 
Special Agent 
United States Attorney’s Office for the 
Southern District of New York 
Sw
orn to before me on 
February ___, 2024 by reliable electronic means, 
Pursuant to Federal Rule of Criminal Procedure 4.1 
_____________________________________ 
TH
E HONORABLE BARBARA MOSES 
United States Magistrate Judge 
Southern District of New York 
9
s/ Jared Eannucci by the Court with permission