United States v. ALIMZHAN TOKHTAKHOUNOV; VADIM TRINCHER; ANATOLY GOLUBCHIK; MICHAEL SALL; STAN GREENBERG; ILLYA TRINCHER, et al., Southern District of New York (Apr. 16, 2013) — Indictment

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
-v. -
ALIMZHAN TOKHTAKHOUNOV, 
a/k/a "Taiwanchik," 
a/k/a "Alik," 
VADIM TRINCHER, 
a/k/a "Dima," 
ANATOLY GOLUBCHIK, 
a/k/a "Tony," 
MICHAEL SALL, 
STAN GREENBERG, 
a/k/a "Slava," 
ILLYA TRINCHER, 
HILLEL NAHMAD, 
a/k/a "Helly," 
JOHN HANSON, 
NOAH SIEGEL, 
a/k/a "The Oracle," 
JONATHAN HIRSCH, 
ARTHUR AZEN, 
DONALD MCCALMONT, 
DMITRY DRUZHINSKY, 
a/k/a "Dima," 
a/k/a "Blondie," 
ALEXANDER ZAVERUKHA, 
a/k/a "Sasha," 
ALEXANDER KATCHALOFF, 
a/k/a "Murushka," 
ANATOLY SHTEYNGROB, 
a/k/a "Tony," 
ILYA ROZENFELD, 
PETER SKYLLAS, 
RONALD UY, 
NICHOLAS HIRSCH, 
BRYAN ZURIFF, 
MOSHE ORATZ, 
KIRILL RAPOPORT, 
DAVID AARON, 
a/k/a "D.A.," 
JUSTIN SMITH, 
ABRAHAM MOSSERI, 
-X 
-    1   -
SEALED 
INDICTMENT 
13 Cr. 

WILLIAM EDLER, 
PETER 
FELDMAN, 
EUGENE TRINCHER, 
EDWIN TING, 
a/k/a "Eddie," 
MOLLY BLOOM, 
WILLIAM BARBALAT, 
YUGESHWAR RAJKUMAR, 
a/k/a "Mateo Hermatte," and 
JOSEPH MANCUSO, 
a/k/a "Joe the Hammer," 
Defendants. 
-    -    -    -    -    -    -    -    -    -    -    -   -    -    -    -    --x 
COUNT ONE 
(Racketeering Conspiracy: Taiwanchik-Trincher Organization) 
The Grand Jury charges: 
The Enterprise 
1. At all times relevant to this Indictment, 
ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM 
TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL 
SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, and 
others known and unknown, were members and associates of the 
"Taiwanchik-Trincher Organization." The Taiwanchik-Trincher 
Organization was a criminal organization whose members and 
associates engaged in crimes including operating an illegal 
gambling business, money laundering, and extortion. 
2. The Taiwanchik-Trincher Organization, including 
its leadership, membership, and associates, constituted an 
-    2   -

"enterprise," as that term is defined in Title 18, United States 
Code, Section 1961(4) --that is, a group of individuals 
associated in fact. This enterprise was engaged in, and its 
activities affected, interstate and foreign commerce. The 
Taiwanchik-Trincher Organization was an international organized 
crime group with leadership based in New York City, Kiev, and 
Moscow, and that operated throughout the United States, 
including in the Southern District of New York, and 
internationally. 
The Taiwanchik-Trincher Organization 
constituted an ongoing organization whose members functioned as 
a continuing unit for a common purpose of achieving the 
objectives of the enterprise. 
3. Most members and associates of the Taiwanchik-
Trincher Organization were born in the former Soviet Union and 
many maintained substantial ties to Ukraine and the Russian 
Federation, including regular travel to Ukraine and the Russian 
Federation, criminal connections to individuals residing in 
Ukraine and the Russian Federation, the transfer of criminal 
proceeds to and from Ukraine and the Russian Federation, the 
purchase of real estate and other assets in Ukraine and the 
Russian Federation with criminal proceeds, and the operation of 
an international gambling business in Ukraine and the former 
Soviet Union. 
-3 -

4. The Taiwanchik-Trincher Organization was led 
principally by three individuals: ALIMZHAN TOKHTAKHOUNOV, a/k/a 
"Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and 
ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants. 
5. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 
"Alik," the defendant, who lived in the Russia Federation, was a 
"vory v zakone," commonly referred to as "Vor" --a Russian term 
translated as "Thief-in-Law" and referring to a member of a 
select group of the highest-level criminal figures from the 
former Soviet Union who receives tribute from other criminals, 
offers protection, and uses his recognized position of authority 
to resolve disputes among criminals. As a Vor, TOKHTAKHOUNOV 
had substantial influence in the criminal underworld and offered 
assistance to and protection of the Taiwanchik-Trincher 
Organization. 
6. The two other leaders of the Taiwanchik-Trincher 
Organization, VADIM TRINCHER, a/k/a "Dima," and ANATOLY 
GOLUBCHIK, a/k/a "Tony," the defendants, were based in New York 
City. TRINCHER and GOLUBCHIK were the principal, though not 
exclusive, leaders of the Taiwanchik-Trincher Organization's 
criminal conduct and ventures, which included an illegal 
gambling business, money laundering, extortion, and other 
crimes. 
TRINCHER and GOLUBCHIK were assisted by numerous 
-    4   -

criminal partners and associates throughout the United States, 
Ukraine, the Russian Federation, and elsewhere. 
The Defendants 
7. Vor ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 
a/k/a "Alik," the defendant, was a powerful figure in former 
Soviet Union organized crime. TOKHTAKHOUNOV rarely left the 
former Soviet Union because he was under indictment by the 
United States Attorney's Office for the Southern District of New 
York on charges related to his role in allegedly bribing 
officials at the 2002 Winter Olympic Games in Salt Lake City, 
Utah. TOKHTAKHOUNOV was a participant in the enterprise, the 
Taiwanchik-Trincher Organization, and was a leader of it. 
TOKHTAKOUNOV used his status as a Vor to resolve disputes with 
clients of the high-stakes illegal gambling operation with 
implicit and sometimes explicit threats of violence and economic 
harm. 
From in or around December 2011 through in or about 
January 2012, TOKHTAKOUNOV was paid $10,000,000 by the 
Taiwanchik-Trincher Organization. 
8. VADIM TRINCHER, a/k/a "Dima," the defendant, was 
a participant in the enterprise, the Taiwanchik-Trincher 
Organization, and was a leader of it. 
In that capacity, 
TRINCHER participated in and profited from various crimes, which 
he committed along with other members and associates of the 
Taiwanchik-Trincher Organization. Among other things, TRINCHER 
-5    -

oversaw a high-stakes illegal sports gambling business that 
catered almost exclusively to oligarchs living in Ukraine and 
the Russian Federation. 
9. ANATOLY GOLUBCHIK, a/k/a "Tony," the defendant, 
was a participant in the enterprise, the Taiwanchik-Trincher 
Organization, and was a leader of the enterprise. 
In that 
capacity, GOLUBCHIK participated in and profited from various 
crimes, which he committed along with other members and 
associates of the Taiwanchik-Trincher Organization. Among other 
things, GOLUBCHIK worked with TRINCHER to oversee the sports 
gambling business and directed members and associates of the 
Taiwanchik-Trincher Organization in laundering tens of millions 
of dollars of profits from that business. 
10. MICHAEL SALL and STAN GREENBERG, a/k/a "Slava," 
the defendants, were United States-based participants in the 
enterprise, the Taiwanchik-Trincher Organization. 
In this 
capacity, these defendants participated in and profited from 
various crimes, including money laundering, which they committed 
along with other members and associates of the Taiwanchik-
Trincher Organization. 
Purposes of the Enterprise 
11. The purposes of the enterprise included the 
following: 
-    6   -

a. enriching the leaders, members, and 
associates of the enterprise through an illegal gambling 
business, money laundering, extortion, and other crimes; 
b. preserving and augmenting the power, 
territory, and financial profits of the enterprise through 
intimidation, violence, and threats of physical and economic 
harm; and 
c. avoiding detection of their illegal conduct 
in order to continue to enrich themselves. 
Means and Methods of the Enterprise 
12. Among the means and methods by which ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and 
STAN GREENBERG, a/k/a "Slava," the defendants, and their co-
conspirators, and other members and associates conducted and 
participated in the conduct of the affairs of the Taiwanchik-
Trincher Organization were the following: 
a. Members and associates of the Taiwanchik-
Trincher Organization and their co-conspirators worked together 
on a range of criminal money-making schemes, including operating 
an international gambling business that catered to oligarchs 
residing in the former Soviet Union and throughout the world. 
-    7   -

b. Members and associates of the Taiwanchik-
Trincher Organization and their co-conspirators used threats of 
violence to obtain unpaid gambling debts from clients. 
c. Members and associates of the Taiwanchik-
Trincher Organization and their co-conspirators employed a 
sophisticated money laundering scheme to move tens of millions 
of dollars in proceeds from the gambling operation from the 
former Soviet Union through shell companies in Cyprus into 
various investments and other shell companies in the United 
States. 
The Racketeering Conspiracy 
13. From at least in or about 2006, up to and 
including on or about the date of this Indictment, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and 
STAN GREENBERG, a/k/a "Slava," the defendants, and others known 
and unknown, in the Southern District of New York and elsewhere, 
being persons employed by and associated with the racketeering 
enterprise described in paragraphs 1 through 12 above, namely, 
the Taiwanchik-Trincher Organization, which enterprise was 
engaged in, and the activities of which affected, interstate and 
foreign commerce, willfully and knowingly combined, conspired, 
confederated, and agreed together and with each other to violate 
Title 18, United States Code, Section 1962(c), to wit, to 
-    8    -

conduct and participate, directly and indirectly, in the conduct 
of such enterprise's affairs through a pattern of racketeering 
activity, as those terms are defined in Title 18, United States 
Code, Sections 1961(1) and 1961(5), and as set forth below in 
paragraph 14. 
It was further a part of the conspiracy that the 
defendants agreed that a conspirator would commit at least two 
acts of racketeering activity in the conduct of the affairs of 
the enterprise. 
The Pattern of Racketeering 
14. The pattern of racketeering activity, as defined 
in Title 18, United States Code, Sections 1961(1) and 1961(5), 
through which ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 
"Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a 
"Tony," MICHAEL SALL, and STAN GREENBERG, a/k/a "Slava," the 
defendants, and their co-conspirators agreed to conduct and 
participate in the conduct of the affairs of the enterprise 
consisted of multiple acts indictable under the following 
federal and state statutes: 
a. Title 18, United States Code, Section 1955 
(operating an illegal gambling business) ; 
b. Title 18, United States Code, Section 1951 
(interference with commerce by threats and violence); 
c. Title 18, United States Code, Sections 1956 
and 1957 (money laundering) ; 
-9 -

d. Title 18, United States Code, Section 1084 
(transmission of wagering information), 
e. Title 18, United States Code, Section 1952 
(interstate and foreign travel and transportation in aid of 
racketeering enterprises); 
f. Title 18, United States Code, Section 894 
(collection of extensions of credit by extortionate means); and 
g. Multiple acts involving gambling, in 
violation of New York Penal Law Section 225.10. 
It was further a part of the conspiracy that the defendants 
agreed that a conspirator would commit at least two acts of 
racketeering activity in the conduct of the affairs of the 
enterprise. 
(Title 18, United States Code, Section 1962(d) .) 
COUNT TWO 
(Racketeering: Taiwanchik-Trincher Organization) 
The Grand Jury further charges: 
15. The allegations contained in paragraphs 1 through 
12 above are hereby repeated, realleged, and incorporated by 
reference herein as though fully set forth at length for the 
purpose of alleging Count Two of this Indictment. 
16. From at least in or about 2006, up to and 
including on or about the date of this Indictment, ALIMZHAN 
-10 -

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 
defendants, and others known and unknown, in the Southern 
District of New York and elsewhere, being persons employed by 
and associated with the racketeering enterprise described in 
paragraphs 1 through 12 above, namely, the Taiwanchik-Trincher 
Organization, which enterprise was engaged in, and the 
activities of which affected, interstate and foreign commerce, 
willfully and knowingly did conduct and participate, directly 
and indirectly, in the conduct of such enterprise's affairs 
through a pattern of racketeering activity as set forth below in 
paragraphs 17 through 24. 
The Pattern of Racketeering 
17. The pattern of racketeering activity, as defined 
in Title 18, United States Code, Sections 1961(1) and 1961(5), 
consisted of the following acts: 
Racketeering Act One: 
Illegal Gambling Business 
18. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 
"Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, 
a/k/a "Tony," the defendants, supervised an international 
bookmaking operation that catered primarily to oligarchs located 
in the former Soviet Union and throughout the world. The 
defendants committed the following acts, any one of which alone 
constitutes the commission of Racketeering Act One: 
-11 -
I 

a. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 
defendants, knowingly and willfully did conduct, finance, 
manage, supervise, direct, and own all and part of an illegal 
gambling business, as that term is defined in Title 18, United 
States Code, Section 1955 (b) (1), (2), and (3), to wit, the 
defendants operated a bookmaking business that violated New York 
Penal Law 225.10, involved five or more persons who conducted, 
financed, managed, supervised, directed, and owned all or part 
of such business, and had been and remained in substantially 
continuous operation for a period in excess of thirty days and 
had a gross revenue of $2,000 in any single day, in violation of 
Title 18, United States Code, Section 1955(a). 
b. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 
defendants, knowingly and willfully did advance and profit from 
unlawful gambling activity by engaging in bookmaking to the 
extent that they received and accepted in any one day more than 
-12 -

five bets totaling more than $5,000, in violation of New York 
Penal Law Section 225.10. 
c. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 
defendants, being engaged in the business of betting and 
wagering, knowingly and willfully did use a wire communication 
facility for the transmission in interstate and foreign commerce 
of bets and wagers and information assisting in the placing of 
bets and wagers on sporting events and contests, and for the 
transmission of wire communications which entitled the recipient 
to receive money and credit as a result of bets and wagers, and 
for information assisting in the placing of bets and wagers, in 
violation of Title 18, United States Code, Section 1084. 
Racketeering Act Two: Extortion Conspiracy 
19. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 
"Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, 
a/k/a "Tony," the defendants, committed the following acts, any 
one of which alone constitutes the commission of Racketeering 
Act Two: 
a. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
-13 -

Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 
defendants, and others known and unknown, willfully and 
knowingly combined, conspired, confederated, and agreed together 
and with each other to commit extortion, as that term is defined 
in Title 18, United States Code, Section 1951 (b) (2), by 
obtaining money and property from and with the consent of 
another person, to wit, clients of their illegal gambling 
business, which consent was and would have been induced by the 
wrongful use of actual and threatened force, violence and fear, 
and thereby would and did obstruct, delay, and affect commerce 
and the movement of articles and commodities in commerce, as 
that term is defined in Title 18, United States Code, Section 
1951(b) (3), in violation of Title 18, United States Code, 
Section 1951. 
b. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 
defendants, and others known and unknown, willfully and 
knowingly combined, conspired, confederated, and agreed together 
and with each other to participate in the use of extortionate 
-14 -

means, as that term is defined in Title 18, United States Code, 
Section 891(7), to collect and attempt to collect extensions of 
credit, as that term is defined in Title 18, United States Code, 
Section 891(1), and to punish persons, to wit, clients of their 
illegal gambling business, for the nonrepayment thereof, in 
violation of Title 18, United States Code, Section 894. 
Racketeering Act Three: Extortion of Client-1 
20. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 
"Alik," the defendant, committed the following acts, any one of 
which alone constitutes the commission of Racketeering Act 
Three: 
a. In or about May 2012, in the Southern 
District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, 
a/k/a "Taiwanchik," a/k/a "Alik," the defendant, and others 
known and unknown, willfully and knowingly did commit and 
attempt to commit extortion, and aid and abet the commission of 
extortion, as that term is defined in Title 18, United States 
Code, Section 1951(b) (2), by attempting to obtain and obtaining 
money and property from and with the consent of "Client-1," a 
client of the enterprise's illegal gambling business, whose 
consent was induced by the wrongful use of actual and threatened 
force, violence, and fear, and thereby attempted to and did 
obstruct, delay, and affect commerce, as that term is defined in 
-15 -

Title 18, United States Code, Section 1951(b) (3), in violation 
of Title 18, United States Code, Sections 1951 and 2. 
b. In or about May 2012, in the Southern 
District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, 
a/k/a "Taiwanchik," a/k/a "Alik," the defendant, and others 
known and unknown, willfully and knowingly did participate in 
the use of extortionate means, as that term is defined in Title 
18, United States Code, Section 891(7), to collect and attempt 
to collect extensions of credit, as that term is defined in 
Title 18, United States Code, Section 891(1), and to punish a 
person, to wit, Client-1, for the nonrepayment thereof, in 
violation of Title 18, United States Code, Section 894. 
Racketeering Act Four: Extortion of Client-2 
21. VADIM TRINCHER, a/k/a "Dima," the defendant, 
committed the following acts, any one of which alone constitutes 
the commission of Racketeering Act Four: 
a. In or about February 2012, in the Southern 
District of New York and elsewhere, VADIM TRINCHER, a/k/a 
"Dima," the defendant, and others known and unknown, willfully 
and knowingly did commit and attempt to commit extortion, and 
aid and abet the commission of extortion, as that term is 
defined in Title 18, United States Code, Section 1951(b) (2), by 
attempting to obtain and obtaining money and property from and 
with the consent of "Client-2," a client of the enterprise's 
-16 -

illegal gambling business, whose consent was induced by the 
wrongful use of actual and threatened force, violence, and fear, 
and thereby attempted to and did obstruct, delay, and affect 
commerce, as that term is defined in Title 18, United States 
Code, Section 1951 (b) (3), in violation of Title 18, United 
States Code, Sections 1951 and 2. 
b. In or about February 2012, in the Southern 
District of New York and elsewhere, VADIM TRINCHER, a/k/a 
"Dima," the defendant, and others known and unknown, willfully 
and knowingly did participate in the use of extortionate means, 
as that term is defined in Title 18, United States Code, Section 
891(7), to collect and attempt to collect extensions of credit, 
as that term is defined in Title 18, United States Code, Section 
891(1), and to punish a person, to wit, Client-2, for the 
nonrepayment thereof, in violation of Title 18, United States 
Code, Section 894. 
Racketeering Act Five: Money Laundering Conspiracy 
22. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 
"Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, 
a/k/a "Tony," the defendants, participated in a sophisticated 
international scheme to launder tens of millions of dollars in 
proceeds from their illegal gambling business through bank 
accounts and shell companies in Cyprus, including from the 
Russia Federation to Cyprus and then back to the Russian 
-17 -

Federation/ and from the Russian Federation to Cyprus and then 
to the United States. 
a. From at least in or about 2006
1 
up to and 
including on or about the date of this Indictment/ in the 
Southern District of New York and elsewhere/ ALIMZHAN 
TOKHTAKHOUN"OV
1 
a/k/a "Taiwanchik
1
11 
a/k/a "Alik
1
11 
VADIM TRINCHERr 
a/k/a "Dimar rr and ANATOLY GOLUBCHIK
1 
a/k/a "Tony
1
11 
the 
defendants/ and others known and unknown/ willfully and 
knowingly combined/ conspired/ confederated/ and agreed together 
and with each other to violate Sections 1956 (a) (1) (B) (i), 
(a) (2) (A) r and (a) (2) (B) (i) r and 1957 of Title 18
1 
United States 
Code. 
b. It was a part and an object of the 
conspiracy that ALIMZHAN TOKHTAKHOUNOV
1 
a/k/a "Taiwanchik
1
11 
a/k/a "Alik
1 
rr VADIM TRINCHER
1 
a/k/a "Dimar rr and ANATOLY 
GOLUBCHIK
1 
a/k/ a "Tony r rr the defendants r and others known and 
unknown/ knowing that the property involved in financial 
transactions represented the proceeds of some form of unlawful 
activity/ willfully and knowingly would and did conduct and 
attempt to conduct financial transactions which in fact involved 
the proceeds of specified unlawful activity/ to wit/ an illegal 
gambling business in violation of Title 18
1 
United States Coder 
Sections 1955 and 1084
1 
and New York Penal Law Section 225.10
1 
knowing that such financial transactions were designed in whole 
-18 -

and in part to conceal and disguise the nature, location, 
source, ownership and control of the proceeds of such specified 
unlawful activity, in violation of Title 18, United States Code, 
Section 1956 (a) (1) (B) (i) 
c. It was further a part and an object of the 
conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 
a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY 
GOLUBCHIK, a/k/a "Tony," the defendants, and others known and 
unknown, willfully and knowingly would and did transport, 
transmit, and transfer, and attempt to transport, transmit, and 
transfer a monetary instrument and funds from a place in the 
United States to and through a place outside the United States 
and to a place in the United States from and through a place 
outside the United States with the intent to promote the 
carrying on of a specified unlawful activity, to wit, an illegal 
gambling business in violation of Title 18, United States Code, 
Sections 1955 and 1084, and New York Penal Law 225.10, all in 
violation of Title 18, United States Code, Section 
1956 (a) (2) (A). 
d. It was further a part and an object of the 
conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 
a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY 
GOLUBCHIK, a/k/a "Tony," the defendants, and others known and 
unknown, willfully and knowingly would and did transport, 
-19 -

transmit, and transfer, and attempt to transport, transmit, and 
transfer monetary instruments and funds from a place in the 
United States to and through a place outside the United States 
and to a place in the United States from and through a place 
outside the United States knowing that the monetary instruments 
and funds involved in the transportations, transmissions, and 
transfers represented the proceeds of some form of unlawful 
activity and knowing that such transportations, transmissions, 
and transfers were designed in whole and in part to conceal and 
disguise the nature, the location, the source, the ownership, 
and the control of the proceeds of a specified unlawful 
activity, to wit, an illegal gambling business in violation of 
Title 18, United States Code, Sections 1955 and 1084, and New 
York Penal Law Section 225.10, all in violation of Title 18, 
United States Code, Section 1956(a) (2) (B) (i). 
e. It was further a part and an object of the 
conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 
a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY 
GOLUBCHIK, a/k/a "Tony," the defendants, and others known and 
unknown, in an offense involving and affecting interstate and 
foreign commerce, would and did knowingly engage in and attempt 
to engage in monetary transactions, as that term is defined in 
Title 18, United States Code, Section 1957(f) (1), in criminally 
derived property that was of a value greater than $10,000, to 
-20 -

wit, wire transfers in excess of $10,000 between bank accounts 
in Cyprus controlled by the defendants and bank accounts in the 
United States controlled by the defendants, such property having 
been derived from a specified unlawful activity, to wit, an 
illegal gambling business in violation of Title 18, United 
States Code, Sections 1955 and 1084, and New York Penal Law 
Section 225.10, all in violation of Title 18, United States 
Code, Section 1957. 
Racketeering Act Six: Interstate and Foreign Travel or 
Transportation in Aid of Racketeering Enterprise 
23. In or about January 2010, in the Southern 
District of New York and elsewhere, VADIM TRINCHER, a/k/a 
"Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, 
knowingly and willfully travelled in interstate and foreign 
commerce and used the mail and a facility in interstate and 
foreign commerce with intent to distribute the proceeds of an 
unlawful activity, that is a business enterprise involving 
gambling in violation of Title 18 United States Code Sections 
1955 and 1084, and New York Penal Law Section 225.10, and did 
distribute the proceeds of that unlawful activity, to wit, 
TRINCHER and GOLUBCHIK caused $3,000,000 in proceeds from their 
illegal gambling business to be sent from a bank account they 
controlled in Cyprus to a bank account they controlled in the 
-21 -

United States, in violation of Title 18, United States Code, 
Section 1952 (a) (1). 
Racketeering Act Seven: Interstate and Foreign Travel and 
Transportation in Aid of Racketeering Enterprise 
24. In or about September 2012, in the Southern 
District of New York and elsewhere, VADIM TRINCHER, a/k/a 
"Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, 
knowingly and willfully travelled in interstate and foreign 
commerce and used the mail and a facility in interstate and 
foreign commerce with intent to distribute the proceeds of an 
unlawful activity, that is a business enterprise involving 
gambling in violation of Title 18 United States Code Sections 
1955 and 1084, and New York Penal Law Section 225.10, and did 
distribute the proceeds of that unlawful activity, to wit, 
TRINCHER and GOLUBCHIK caused approximately $2,200,000 in 
proceeds from their illegal gambling business to be sent from a 
bank account they controlled in Cyprus to a bank account they 
controlled in the United States, in violation of Title 18, 
United States Code, Section 1952(a) (1). 
(Title 18, United States Code, Section 1962(c) .) 
-22 -

COUNT THREE 
(Racketeering Conspiracy: Nahrnad-Trincher Organization) 
The Grand Jury further charges: 
The Enterprise 
25. At all times relevant to this Indictment, ILLYA 
TRINCHER, HILLEL 
NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 
Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD 
MCCALMONT, the defendants, and others known and unknown, were 
members and associates of the "Nahmad-Trincher Organization." 
The Nahmad-Trincher Organization was a criminal organization 
whose members and associates engaged in crimes, including 
conducting an illegal gambling business, money laundering, and 
extortion. 
26. The Nahmad-Trincher Organization, including its 
leadership, membership, and associates, constituted an 
"enterprise," as that term is defined in Title 18, United States 
Code, Section 1961(4) --that is, a group of individuals 
associated in fact. This enterprise was engaged in, and its 
activities affected, interstate and foreign commerce. The 
Nahmad-Trincher Organization was an organized crime group with 
leadership based in New York City and Los Angeles, and that 
operated throughout the United States, including in the Southern 
District of New York, and internationally. 
The Nahmad-Trincher 
Organization constituted an ongoing organization whose members 
-23 -

functioned as a continuing unit for a common purpose of 
achieving the objectives of the enterprise. 
27. The criminal conduct of the Nahmad-Trincher 
Organization was directed principally, though not exclusively, 
by its leaders: ILLYA TRINCHER, son of VADIM TRINCHER, a/k/a 
"Dima," HILLEL NAHMAD, a/k/a "Helly," and NOAH SIEGEL, a/k/a 
"The Oracle," the defendants, who were based in New York City. 
ILLYA TRINCHER, NAHMAD, and SIEGEL worked together to lead 
multiple related criminal ventures including an illegal gambling 
business, money laundering, and other crimes. TRINCHER, NAHMAD, 
and SIEGEL were assisted by numerous criminal partners and 
associates throughout the United States, Europe, and elsewhere. 
28. The Nahmad-Trincher Organization was a high-
stakes illegal gambling business run out of New York City and 
Los Angeles that catered primarily to multi-millionaire and 
billionaire clients. The Nahmad-Trincher Organization used 
online gambling websites, operating illegally in the United 
States, to operate an illegal gambling business that generated 
tens of millions of dollars in bets each year. 
29. The Nahmad-Trincher Organization laundered the 
proceeds of the gambling operation through a host of American 
bank accounts and Titan P & H LLC ("Titan"), a plumbing company 
in the Bronx that the Nahmad-Trincher Organization acquired a 
fifty percent interest in as repayment of a gambling debt. 
-24 -

30. The Nahmad-Trincher Organization was financed by 
a number of different individuals and entities, including the 
Helly Nahmad Gallery in New York City, an art gallery operated 
by HILLEL NAHMAD, a/k/a "Helly," the defendant, in the Carlyle 
Hotel in New York City; NAHMAD's father, a billionaire art 
dealer located in Europe; and JH Capital Inc., an investment 
firm run by JOHN HANSON, the defendant. 
The Defendants 
31. ILLYA TRINCHER, the defendant, was a participant 
in the enterprise, the Nahmad-Trincher Organization, and was a 
leader of the enterprise. 
In that capacity, TRINCHER 
participated in and profited from various crimes, which he 
committed along with other members and associates of the Nahmad-
Trincher Organization. Among other things, TRINCHER oversaw a 
high-stakes illegal gambling business. 
32. HILLEL NAHMAD, a/k/a "Helly," the defendant, was 
a participant in the enterprise, the Nahmad-Trincher 
Organization, and was a leader of the enterprise. In that 
capacity, NAHMAD participated in and profited from various 
crimes, which he committed along with other members and 
associates of the Nahmad-Trincher Organization. Among other 
things, NAMHAD worked with TRINCHER to launder tens of millions 
of dollars on behalf of the illegal gambling business. 
-25 -

33. NOAH SIEGEL, a/k/a "The Oracle," the defendant, 
was a participant in the enterprise, the Nahmad-Trincher 
Organization, and was a leader of the enterprise. In that 
capacity, SIEGEL participated in and profited from various 
crimes, which he committed along with other members and 
associates of the Nahmad-Trincher Organization. Among other 
things, SIEGEL worked with TRINCHER to oversee a high-stakes 
illegal gambling business. 
34. JOHN HANSON, ARTHUR AZEN, JOHN HIRSCH, and DON 
MCCALMONT, the defendants, were also participants in the 
enterprise, the Nahmad-Trincher Organization. 
In this capacity, 
these defendants participated in and profited from various 
crimes, including operating an illegal gambling business and 
money laundering, which they committed along with other members 
and associates of the Nahmad-Trincher Organization. 
Purposes of the Enterprise 
35. The purposes of the enterprise included the 
following: 
a. enriching the leaders, members, and 
associates of the enterprise through an illegal gambling 
business, money laundering, extortion, and other crimes; and 
b. avoiding detection of their illegal conduct 
in order to continue to enrich themselves. 
-26 -

Means and Methods of the Enterprise 
36. Among the means and methods by which ILLYA 
TRINCHER, HILLEL 
NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 
Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD 
MCCALMONT, the defendants, and their co-conspirators, and other 
members and associates conducted and participated in the conduct 
of the affairs of the Nahmad-Trincher Organization were the 
following: 
a. Members and associates of the Nahmad-
Trincher Organization and their co-conspirators worked together 
on a range of criminal money-making schemes, including operating 
an illegal international gambling business that catered to 
multi-millionaires and billionaires. 
b. Members and associates of the Nahmad-
Trincher Organization and their co-conspirators employed a 
sophisticated money laundering scheme to launder tens of 
millions of dollars through various bank accounts and 
corporations, including Titan. 
The Racketeering Conspiracy 
37. From at least in or about 2006, up to and 
including on or about the date of this Indictment, ILLYA 
TRINCHER, HILLEL 
NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 
Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD 
MCCALMONT, the defendants, and others known and unknown, in the 
-27 -

Southern District of New York and elsewhere, being persons 
employed by and associated with the racketeering enterprise 
described in paragraphs 25 through 34 above, namely, the Nahmad-
Trincher Organization, which enterprise was engaged in, and the 
activities of which affected, interstate and foreign commerce, 
willfully and knowingly combined, conspired, confederated, and 
agreed together and with each other to violate Title 18, United 
States Code, Section 1962(c), to wit, to conduct and 
participate, directly and indirectly, in the conduct of such 
enterprise's affairs through the collection of unlawful debt as 
set forth in paragraph 38 below, and through a pattern of 
racketeering activity as set forth below in paragraph 39. 
Collection of Unlawful Debt 
38. The collection of unlawful debt, as that term is 
defined in Title 18, United States Coder Section 1961(6) r 
through which the defendants and their co-conspirators agreed to 
conduct and participate directly and indirectly in the conduct 
of the affairs of the enterpriser consisted of the collection of 
unlawful gambling debts/ that isr debts incurred and contracted 
in gambling activity which was in violation of the law of the 
United States and the law of the State of New York and which was 
incurred in connection with a business of gambling in violation 
of the law of the United States and the law of the State of New 
York. It was a part of the conspiracy that each defendant 
-28 -

agreed that a conspirator would commit at least one collection 
of unlawful debt in the conduct of the affairs of the 
enterprise. 
The Pattern of Racketeering 
39. The pattern of racketeering activity, as defined 
in Title 18, United States Code, Sections 1961(1) and 1961(5), 
through which ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH 
SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR 
AZEN, and DONALD MCCALMONT, the defendants, and .their co-
conspirators agreed to conduct and participate in the conduct of 
the affairs of the enterprise consisted of multiple acts 
indictable under the following federal and state statutes: 
a. Title 18, United States Code, Section 1955 
(operation of an illegal gambling business); 
b. Title 18, United States Code, Sections 1956 
and 1957 (money laundering); 
c. Title 18, United States Code, Section 1084 
(transmission of wagering information) ; 
d. Title 18, United States Code, Section 1952 
(interstate and foreign travel and transportation in aid of 
racketeering enterprises); 
e. 
Title 18, United States Code, Section 894 
(collection of extensions of credit by extortionate means); and 
-29 -

f. multiple acts involving gambling, in 
violation of New York Penal Law Section 225.10. 
It was further a part of the conspiracy that the defendants 
agreed that a conspirator would commit at least two acts of 
racketeering activity in the conduct of the affairs of the 
enterprise. 
(Title 18, United States Code, Section 1962(d) .) 
COUNT FOUR 
(Racketeering: Nahmad-Trincher Organization) 
The Grand Jury further charges: 
40. The allegations contained in paragraphs 25 
through 39 above are hereby repeated, realleged, and 
incorporated by reference herein as though fully set forth at 
length for the purpose of alleging Count Four of this 
Indictment. 
41. From at least in or about 2006, up to and 
including on or about the date of this Indictment ILLYA 
TRINCHER, HILLEL 
NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 
Oracle," ARTHUR AZEN, DON MCCALMONT and JOHN HANSON, the 
defendants, and others known and unknown, in the Southern 
District of New York and elsewhere, being persons employed by 
and associated with the racketeering enterprise described in 
paragraphs 25 through 39 above, namely, the Nahmad-Trincher 
-30 -

Organization, which enterprise was engaged in, and the 
activities of which affected, interstate and foreign commerce, 
willfully and knowingly did conduct and participate, directly 
and indirectly, in the conduct of such enterprise's affairs 
through a pattern of racketeering activity, as described in 
paragraphs 42 through 49, and the collection of unlawful debt, 
as described in paragraph 50. 
The Pattern of Racketeering 
42. The pattern of racketeering activity, as defined 
in Title 18, United States Code, Sections 1961(1) and 1961(5), 
consisted of the following acts: 
Racketeering Act One: Illegal Gambling Business 
43. ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 
NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the 
defendants, operated an illegal international gambling business 
that catered primarily to celebrities, professional poker 
players, and very wealthy individuals working in the financial 
industry. 
The defendants committed the following acts, any of 
which alone constitutes the commission of Racketeering Act One: 
a. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ILLYA TRINCHER, 
HILLEL 
NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," 
and JOHN HANSON, the defendants, knowingly and willfully did 
-31 -

conduct, finance, manage, supervise, direct, and own all and 
part of an illegal gambling business, as that term is defined in 
Title 18, United States Code, Section 1955 (b) (1), (2), and (3), 
to wit, the defendants operated a bookmaking business which 
violated New York Penal Law 225.10, involved five or more 
persons who conducted, financed, managed, supervised, directed, 
and owned all or part of such business, and had been and 
remained in substantially continuous operation for a period in 
excess of thirty days and had a gross revenue of $2,000 in any 
single day, in violation of Title 18 United States Code, Section 
1955 (a) . 
b. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ILLYA TRINCHER, 
HILLEL 
NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," 
and JOHN HANSON, the defendants, knowingly and willfully did 
advance and profit from unlawful gambling activity by engaging 
in bookmaking to the extent that they received and accepted in 
any one day more than five bets totaling more than $5,000, in 
violation of New York Penal Law Section 225.10. 
c. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ILLYA TRINCHER, 
HILLEL 
NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," 
-32 -

and JOHN HANSON, the defendants, knowingly and willfully being 
engaged in the business of betting and wagering, did use a wire 
communication facility for the transmission in interstate and 
foreign commerce of bets and wagers and information assisting in 
the placing of bets and wagers on sporting events and contests, 
and for the transmission of wire communications which entitled 
the recipient to receive money and credit as a result of bets 
and wagers, and for information assisting in the placing of bets 
and wagers, in violation of Title 18, United States Code, 
Section 1084. 
Racketeering Act Two: Extortion of Client-3 
44. From at least in or about 2010, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ILLYA TRINCHER, DON 
MCCALMONT, ARTHUR AZEN, and JOHN HANSON, the defendants, and 
others known and unknown, willfully and knowingly did 
participate in the use of extortionate means, as that term is 
defined in Title 18, United States Code, Section 891(7), to 
collect and attempt to collect extensions of credit, as that 
term is defined in Title 18, United States Code, Section 891(1), 
and to punish a person, to wit, "Client-3," for the nonrepayment 
thereof, in violation of Title 18, United States Code, Section 
894 (a) (1) and (2). 
-33 -

Racketeering Act Three: Money Laundering Conspiracy 
45. ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 
NOAH SIEGEL, a/k/a "The Oracle," DON MCCALMONT, ARTHUR AZEN, and 
JOHN HANSON, the defendants, participated in an international 
conspiracy to launder tens of millions of dollars in proceeds 
from their illegal gambling business. From at least in or about 
2006, up to and including on or about the date of this 
Indictment, in the Southern District of New York and elsewhere, 
ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a 
"The Oracle," and JOHN HANSON, the defendants, and others known 
and unknown, willfully and knowingly combined, conspired, 
confederated, and agreed together and with each other to violate 
Sections 1956 (a) (1) (A) (i), (a) (1) (A) (ii), (a) (1) (B) (i), 
(a) (2) (A), and (a) (2) (B) (i), and 1957 of Title 18, United States 
Code. 
a. It was a part and an object of the conspiracy 
that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, 
a/k/a "The Oracle," and JOHN HANSON, the defendants, and others 
known and unknown, knowing that the property involved in 
financial transactions represented the proceeds of some form of 
unlawful activity, willfully and knowingly would and did conduct 
and attempt to conduct financial transactions which in fact 
involved the proceeds of specified unlawful activity, to wit, an 
illegal gambling business in violation of Title 18, United 
-34 -

States Code, Sections 1955 and 1084, and New York Penal Law 
Section 225.10, knowing that such financial transactions were 
conducted with the intent to promote the carrying on of 
specified unlawful activity, to wit, an illegal gambling 
business, in violation of Title 18, United States Code, Section 
1956 (a) (1) (A) (i). 
b. It was further a part and an object of the 
conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 
NOAH SIEGEL, a/k/a "The Oracle," ARTHUR AZEN, DON MCCALMONT, and 
JOHN HANSON, the defendants, and others known and unknown, 
knowing that the property involved in financial transactions 
represented the proceeds of some form of unlawful activity, 
willfully and knowingly would and did conduct and attempt to 
conduct financial transactions which in fact involved the 
proceeds of specified unlawful activity, to wit, an illegal 
gambling business in violation of Title 18, United States Code, 
Sections 1955 and 1084, and New York Penal Law Section 225.10, 
knowing that such financial transactions were conducted with the 
intent to engage in conduct constituting a violation of sections 
7201 and 7206 of the Internal Revenue Code of 1986, in violation 
of Title 18, United States Code, Section 1956(a) (1) (A) (ii). 
c. It was further a part and an object of the 
conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 
NOAH SIEGEL, a/k/a "The Oracle," ARTHUR AZEN, DON MCCALMONT, and 
-35 -

JOHN HANSON, the defendants, and others known and unknown, 
knowing that the property involved in financial transactions 
represented the proceeds of some form of unlawful activity 
willfully and knowingly would and did conduct and attempt to 
conduct financial transactions which in fact involved the 
proceeds of specified unlawful activity, to wit, an illegal 
gambling business in violation of Title 18, United States Code, 
Sections 1955 and 1084, and New York Penal Law Section 225.10, 
knowing that such financial transactions were designed in whole 
and in part to conceal and disguise the nature, location, 
source, ownership and control of the proceeds of specified 
unlawful activity, in violation of Title 18, United States Code, 
Section 1956(a) (1) (B) (i) 
d. It was further a part and an object of the 
conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 
NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the 
defendants, and others known and unknown, willfully and 
knowingly would and did transport, transmit, and transfer, and 
attempt to transport, transmit, and transfer a monetary 
instrument and funds from a place in the United States to and 
through a place outside the United States and to a place in the 
United States from and through a place outside the United States 
with the intent to promote the carrying on of a specified 
unlawful activity, to wit, an illegal gambling business in 
-36 -

violation of Title 18, United States Code, Sections 1955 and 
1084, and New York Penal Law Section 225.10, all in violation of 
Title 18, United States Code, Section 1956(a) (2) (A). 
e. It was further a part and an object of the 
conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 
NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the 
defendants, and others known and unknown, in an offense 
involving and affecting interstate and foreign commerce, would 
and did engage in and attempt to engage in monetary 
transactions, as that term is defined in Title 18, United States 
Code, Section 1957(f) (1), in criminally derived property that 
was of a value greater than $10,000, to wit, wire transfers in 
excess of $10,000 between various bank accounts controlled by 
the defendants and clients of the illegal gambling business, 
such property having been derived from a specified unlawful 
activity, to wit, an illegal gambling business in violation of 
Title 18, United States Code, Sections 1955 and 1084, and New 
York Penal Law Section 225.10, all in violation of Title 18, 
United States Code, Section 1957. 
Racketeering Act Four: Interstate and Foreign Travel and 
Transportation in Aid of Racketeering Enterprise 
46. On or about September 12, 2012, in the Southern 
District of New York and elsewhere, HILLEL NAHMAD, a/k/a "Helly 
Nahmad," the defendant, knowingly and willfully travelled in 
-37 -

interstate and foreign commerce and used the mail and a facility 
in interstate and foreign commerce with intent to otherwise 
promote, manage, establish, carry on, and facilitate the 
promotion, management, establishment, and carrying on, of an 
unlawful activity, that is a business enterprise involving 
gambling in violation of Title 18 United States Code Sections 
1955 and 1084, and New York Penal Law Section 225.10, and did 
promote, manage, establish, carry on, and facilitate the 
promotion, management, establishment, and carrying on of an 
unlawful activity, to wit, NAHMAD caused $500,000 to be sent 
from his father's bank account in Switzerland to ILLYA TRINCHER, 
the defendant, in the United States, in violation of Title 18, 
United States Code, Section 1952(a) (1). 
Racketeering Act Five: Interstate and Foreign Travel and 
Transportation in Aid of Racketeering Enterprise 
47. On or about September 12, 2012, in the Southern 
District of New York and elsewhere, ILLYA TRINCHER, the 
defendant, knowingly and willfully travelled in interstate and 
foreign commerce and used the mail and a facility in interstate 
and foreign commerce with intent to otherwise promote, manage, 
establish, carry on, and facilitate the promotion, management, 
establishment, and carrying on, of an unlawful activity, that is 
a business enterprise involving gambling in violation of Title 
18 United States Code Sections 1955 and 1084, and New York Penal 
-38 -

Law Section 225.10
1 
and did promoter manager establish/ carry 
on
1 
and facilitate the promotion/ management/ establishment/ and 
carrying on of an unlawful activity/ to witr TRINCHER caused 
four hundred/ $99
1
800 to be sent from his bank account in New 
York to an account in Taiwan that was controlled by an online 
gambling website operating illegally in the United States
1 
in 
violation of Title 18
1 
United States Code
1 
Section 1952(a) (1) 
Racketeering Act Six: Interstate and Foreign Travel and 
Transportation in Aid of Racketeering Enterprise 
48. On or about June 4
1 
2011
1 
in the Southern 
District of New York and elsewhere/ HILLEL NAHMAD
1 
a/k/a "Helly 
Nahmad
1
11 
the defendant
1 
knowingly and willfully travelled in 
interstate and foreign commerce and used the mail and a facility 
in interstate and foreign commerce with intent to otherwise 
promoter manager establish/ carry onr and facilitate the 
promotion/ management/ establishment/ and carrying onr of an 
unlawful activity/ that is a business enterprise involving 
gambling in violation of Title 18 United States Code Sections 
1955 and 1084
1 
and New York Penal Law Section 225.10
1 
and did 
promoter manager establish/ carry onr and facilitate the 
promotion/ management/ establishment/ and carrying on of an 
unlawful activity/ to witr NAHMAD caused $850
1
000 to be sent 
from his father
1
S bank account in Switzerland to a bank account 
under the control of NOAH SIEGEL
1 
a/k/a "the Oracle
1
11 
in the 
-39 -

United States, in violation of Title 18, United States Code, 
Section 1952 (a) (1) 
Racketeering Act Seven: 
Transmission of Wagering Information 
49. ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 
NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the 
defendants, were in the business of illegally betting on 
professional sporting events and placed millions of dollars of 
bets through online gambling websites operating illegally in the 
United States. From at least in or about 2008, up to and 
including on or about the date of this indictment, in the 
Southern District of New York and elsewhere, ILLYA TRINCHER, 
HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," 
and JOHN HANSON, the defendants, knowingly and willfully being 
engaged in the business of betting and wagering, did use a wire 
communication facility for the transmission in interstate and 
foreign commerce of bets and wagers and information assisting in 
the placing of bets and wagers on sporting events and contests, 
and for the transmission of wire communications which entitled 
the recipient to receive money and credit as a result of bets 
and wagers, and for information assisting in the placing of bets 
and wagers, in violation of Title 18, United States Code, 
Section 1084. 
-40 -

Collection of Unlawful Debt 
50. The collection of unlawful debt defined by Title 
18, United States Code, Section 1961(6), that is, a debt (A) 
incurred and contracted in gambling activity which was in 
violation of a law of the United States of America and a law of 
the State of New York, and (B) which was incurred in connection 
with the business of gambling in violation of a law of the 
United States of America, New York State, and a political 
subdivision thereof, through which ILLYA TRINCHER, HILLEL 
NAHMAD, a/k/a "Belly," NOAH SIEGEL, a/k/a "The Oracle," JOHN 
HANSON, ARTHUR AZEN, and DONALD MCCALMONT, the defendants, did 
conduct and participate in the affairs of the enterprise, which 
was engaged in and the activities of which affected interstate 
commerce, consisted of collecting and attempting to collect an 
unlawful debt as follows: 
a. From at least in or about 2010, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ILLYA TRINCHER, 
HILLEL 
NAHMAD, a/k/a "Belly," NOAH SIEGEL, a/k/a "The Oracle," 
ARTHUR AZEN, DON MCCALMONT, and JOHN HANSON, the defendants, 
participated in the collection and attempted collection of more 
than $2,000,000 of unlawful gambling debts from Client-3 by, 
among other things, acquiring a fifty percent interest in 
Client-3's plumbing company, Titan. 
-41 -

(Title 18, United States Code, Section 1962(c) .) 
COUNT FIVE 
(Illegal Sports Gambling Business: 
Taiwanchik-Trincher Organization) 
The Grand Jury further charges: 
51. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 
defendants, knowingly and willfully did conduct, finance, 
manage, supervise, direct, and own all and part of an illegal 
gambling business, as that term is defined in Title 18, United 
States Code, Section 1955 (b) (1), (2), and (3), to wit, the 
defendants operated a bookmaking business that violated New York 
Penal Law Section 225.10, involved five or more persons who 
conducted, financed, managed, supervised, directed, and owned 
all or part of such business, and had been and remained in 
substantially continuous operation for a period in excess of 
thirty days and had a gross revenue of $2,000 in any single day. 
(Title 18, United States Code, Sections 1955 and 2.) 
-42 -

COUNT SIX 
(Acceptance of Financial Instrument for Unlawful Internet 
Gambling: Taiwanchik-Trincher Organization) 
The Grand Jury further charges: 
52. From at least in or about 2007, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM TRINCHER, a/k/a 
"Dima," and ANATOLY GOLUBCHIK, the defendants, who were engaged 
in the business of betting and wagering, knowingly and willfully 
did accept, in connection with the participation of another 
person in unlawful Internet gambling, credit, and the proceeds 
of credit, extended to and on behalf of such other person 
(including credit extended through the use of a credit card); an 
electronic fund transfer, and funds transmitted by and through a 
money transmitting business, and the proceeds of an electronic 
fund transfer and money transmitting service, from and on behalf 
of such other person; a check, draft, and similar instrument 
which was drawn by and on behalf of such other person and was 
drawn on and payable at and through a financial institution; and 
the proceeds of another form of financial transaction, as the 
Secretary and the Board of Governors of the Federal Reserve 
System may jointly prescribe by regulation, which involves a 
financial institution as a payor and financial intermediary on 
-43 -

behalf of and for the benefit of such other person, to wit, 
TOKHTAKHOUNOV, TRINCHER, and GOLUBCHIK operated an illegal 
bookmaking business that utilized gambling websites operating 
illegally in the United States. 
(Title 31, United States Code, Sections 5363 and 5366; 
Title 18, United States Code, Section 2.) 
COUNT SEVEN 
(Money Laundering Conspiracy: Taiwanchik-Trincher Organization) 
The Grand Jury further charges: 
53. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and 
SLAVA GREENBERG, a/k/a "Stan," the defendants, and others known 
and unknown, willfully and knowingly combined, conspired, 
confederated, and agreed together and with each other to violate 
Title 18, United States Code, Sections 1956 (a) (1) (B) (i), 
(a) (2) (A), and (a) (2) (B) (i), and 1957, to wit, the defendants 
laundered more than $50,000,000 in sports gambling proceeds 
through shell companies in Cyprus and the United States of 
America. 
54. It was a part and an object of the conspiracy 
that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," 
-44 -

VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," 
MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," the defendants, 
and others known and unknown, knowing that the property involved 
in financial transactions represented the proceeds of some form 
of unlawful activity willfully and knowingly would and did 
conduct and attempt to conduct financial transactions which in 
fact involved the proceeds of specified unlawful activity, to 
wit, an illegal gambling business in violation of Title 18, 
United States Code, Sections 1955 and 1084, and New York Penal 
Law Section 225.10, knowing that such financial transactions 
were designed in whole and in part to conceal and disguise the 
nature, location, source, ownership and control of the proceeds 
of specified unlawful activity, in violation of Title 18, United 
States Code, Section 1956(a) (1) (B) (i). 
55. It was further a part and an object of the 
conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 
a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, 
a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," 
the defendants, and others known and unknown, willfully and 
knowingly would and did transport, transmit, and transfer, and 
attempt to transport, transmit, and transfer a monetary 
instrument and funds from a place in the United States to and 
through a place outside the United States and to a place in the 
United States from and through a place outside the United States 
-45 -

with the intent to promote the carrying on of a specified 
unlawful activity, to wit, an illegal gambling business in 
violation of Title 18, United States Code, Sections 1955 and 
1084, and New York Penal Law Section 225.10, all in violation of 
Title 18, United States Code, Section 1956 (a) (2) (A). 
56. It was further a part and an object of the 
conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 
a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, 
a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," 
the defendants, and others known and unknown, willfully and 
knowingly would and did transport, transmit, and transfer, and 
attempt to transport, transmit, and transfer monetary 
instruments and funds from a place in the United States to and 
through a place outside the United States and to a place in the 
United States from and through a place outside the United States 
knowing that the monetary instruments and funds involved in the 
transportations, transmissions, and transfers represented the 
proceeds of some form of unlawful activity and knowing that such 
transportations, transmissions, and transfers were designed in 
whole and in part to conceal and disguise the nature, the 
location, the source, the ownership, and the control of the 
proceeds of a specified unlawful activity, to wit, an illegal 
gambling business in violation of Title 18, United States Code, 
Sections 1955 and 1084, and New York Penal Law Section 225.10, 
-46 -

all in violation of Title 18, United States Code, Section 
1956 (a) (2) (B) (i). 
57. It was further a part and an object of the 
conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 
a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, 
a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," 
the defendants, and others known and unknown, in an offense 
involving and affecting interstate and foreign commerce, would 
and did engage in and attempt to engage in monetary 
transactions, as that term is defined in Title 18, United States 
Code, Section 1957(f) (1), in criminally derived property that 
was of a value greater than $10,000, to wit, wire transfers in 
excess of $10,000 between bank accounts in Cyprus controlled by 
the defendants and bank accounts in the United States controlled 
by the defendants, such property having been derived from a 
specified unlawful activity, to wit, an illegal gambling 
business in violation of Title 18, United States Code, Sections 
1955 and 1084, and New York Penal Law Section 225.10, all in 
violation of Title 18, United States Code, Section 1957. 
(Title 18, United States Code, Section 1956(h) .) 
COUNT EIGHT 
(To Collect Extensions of Credit by Extortionate Means) 
The Grand Jury further charges: 
-47 -

58. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, 
and others known and unknown, knowingly and willfully combined, 
conspired, confederated, and agreed together and with each other 
to participate in the use of extortionate means, as that term is 
defined in Title 18, United States Code, Section 891(7), to 
collect and attempt to collect extensions of credit, as that 
term is defined in Title 18, United States Code, Section 891(1), 
and to punish a person, to wit, gamblers who owed sports 
gambling debts, for the nonrepayrnent thereof, to wit, 
TOKHTAKHOUNOV, TRINCHER, and GOLUBCHIK, agreed to use violence 
and threats of violence to collect sports gambling debts from 
gamblers. 
(Title 18, United States Code, Section 894.) 
COUNT NINE 
(Illegal Sports Gambling Business: 
Nahmad-Trincher Organization) 
The Grand Jury further charges: 
59. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, HILLEL NAHMAD, 
-48 -

a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," 
JOHN HANSON, JONATHAN HIRSCH, JUSTIN SMITH, WILLIAM EDLER, PETER 
FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a "D.A.," BRYAN ZURIFF, 
and ABRAHAM MOSSERI, the defendants, knowingly and willfully did 
conduct, finance, manage, supervise, direct, and own all and 
part of an illegal gambling business, as that term is defined in 
Title 18, United States Code, Section 1955 (b) (1), (2), and (3), 
and aid and abet the same, to wit, NAHMAD, TRINCHER, SIEGEL, 
HANSON, HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, AARON, ZURIFF, and 
MOSSERI, operated a bookmaking business that violated New York 
Penal Law Section 225.10, involved five or more persons who 
conducted, financed, managed, supervised, directed, and owned 
all or part of such business, and had been and remained in 
substantially continuous operation for a period in excess of 
thirty days and had a gross revenue of $2,000 in any single day. 
(Title 18, United States Code, Sections 1955 and 2.) 
COUNT TEN 
(Transmission of Sports Wagering Information: 
Nahmad-Trincher Organization) 
The Grand Jury further charges: 
60. From at least in or about 2008, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, HILLEL NAHMAD, 
a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," 
-49 -

JOHN HANSON, and JONATHAN HIRSCH, the defendants, being engaged 
in the business of betting and wagering, knowingly and willfully 
did use a wire communication facility for the transmission in 
interstate and foreign commerce of bets and wagers and 
information assisting in the placing of bets and wagers on a 
sporting event and contest, and for the transmission of a wire 
communication which entitled the recipient to receive money and 
credit as a result of bets and wagers, and for information 
assisting in the placing of bets and wagers, and aided and 
abetted the same, to wit, NAHMAD, TRINCHER, SIEGEL, HANSON, 
HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, AARON, ZURIFF, and 
MOSSERI, the defendants transmitted wagering information 
concerning sporting events via emails sent across state lines. 
(Title 18, United States Code, Sections 1084 and 2.) 
COUNT ELEVEN 
(Acceptance of Financial Instrument for Unlawful Internet 
Sports Gambling: Trincher-Nahmad Organization) 
The Grand Jury further charges: 
61. From at least in or about 2008, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, HILLEL NAHMAD, 
a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," 
JOHN HANSON, JONATHAN HIRSCH, a/k/a "Hersch," JUSTIN SMITH, 
WILLIAM EDLER, 
PETER FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a 
-50 -

"D.A. ," BRYAN ZURIFF, and ABRAHAM MOSSERI, the defendants, who 
were engaged in the business of betting and wagering, knowingly 
and willfully did accept, in connection with the participation 
of another person in unlawful Internet gambling, credit, and the 
proceeds of credit, extended to and on behalf of such other 
person (including credit extended through the use of a credit 
card); an electronic fund transfer, and funds transmitted by and 
through a money transmitting business, and the proceeds of an 
electronic fund transfer and money transmitting service, from 
and on behalf of such other person; a check, draft, and similar 
instrument which was drawn by and on behalf of such other person 
and was drawn on and payable at and through a financial 
institution; and the proceeds of another form of financial 
transaction, as the Secretary and the Board of Governors of the 
Federal Reserve System may jointly prescribe by regulation, 
which involved a financial institution as a payor and financial 
intermediary on behalf of and for the benefit of such other 
person, and aided and abetted the same, to wit, NAHMAD, 
TRINCHER, SIEGEL, HANSON, HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, 
AARON, ZURIFF, and MOSSERI, operated an illegal bookmaking 
business that utilized gambling websites operating illegally in 
the United States. 
(Title 31, United States Code, Sections 5363 and 5366; 
Title 18, United States Code, Section 2.) 
-51 -< 
i 
! 

COUNT TWELVE 
(Money Laundering Conspiracy: Nahmad-Trincher Organization) 
The Grand Jury further charges: 
62. From at least in or about 2006, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, HILLEL NAHMAD, 
a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," 
JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, EDWIN TING, a/k/a 
"Eddie," EUGENE TRINCHER, PETER SKYLLAS, and RONALD UY, the 
defendants, and others known and unknown, knowingly and 
willfully did combine, conspire, confederate, and agree together 
and with each other to violate Title 18, United States Code, 
Sections, 1956(a) (1) (A) (i), (a) (1) (A) (ii), (a) (1) (B) (i), 
(a) (2) (A), and (a) (2) (B) (i), and 1957 of Title 18, United States 
Code .. 
63. It was a part and an object of the conspiracy 
that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, 
a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, 
EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER SKYLLAS, and 
RONALD UY, the defendants, and others known and unknown, knowing 
that the property involved in financial transactions represented 
the proceeds of some form of unlawful activity, willfully and 
knowingly would and did conduct and attempt to conduct financial 
-52 -

transactions which in fact involved the proceeds of specified 
unlawful activity, to wit, an illegal gambling business in 
violation of Title 18, United States Code, Sections 1955 and 
1084, and New York Penal Law Sections 225.10, knowing that such 
financial transactions were conducted with the intent to promote 
the carrying on of specified unlawful activity, to wit, an 
illegal gambling business, to wit the defendants laundered more 
than $50,000,000 in gambling proceeds through various bank 
accounts and businesses, in violation of Title 18, United States 
Code, Section 1956 (a) (1) (A) (i). 
64. It was further a part and an object of the 
conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, 
NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON 
MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER 
SKYLLAS, 
and RONALD UY, the defendants, and others known and 
unknown, knowing that the property involved in financial 
transactions represented the proceeds of some form of unlawful 
activity, willfully and knowingly would and did conduct and 
attempt to conduct financial transactions which in fact involved 
the proceeds of specified unlawful activity, to wit, an illegal 
gambling business in violation of Title 18, United States Code, 
Sections 1955 and 1084, and New York Penal Law Section 225.10, 
knowing that such financial transactions were conducted with the 
intent to engage in conduct constituting a violation of section 
-53 -

7201 and 7206 of the Internal Revenue Code of 1986, in violation 
of Title 18, United States Code, Section 1956(a) (1) (A) (ii). 
65. It was further a part and an object of the 
conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, 
NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON 
MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER 
SKYLLAS, and RONALD UY, the defendants, and others known and 
unknown, knowing that the property involved in such financial 
transactions represented the proceeds of some form of unlawful 
activity, willfully and knowingly would and did conduct and 
attempt to conduct financial transactions which in fact involved 
the proceeds of specified unlawful activity, to wit, an illegal 
gambling business in violation of Title 18, United States Code, 
Sections 1955 and 1084, and New York Penal Law Section 225.10, 
knowing that such financial transactions were designed in whole 
and in part to conceal and disguise the nature, location, 
source, ownership and control of the proceeds of specified 
unlawful activity, in violation of Title 18, United States Code, 
Section 1956 (a) (1) (B) (i). 
66. It was further a part and an object of the 
conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, 
NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, and RONALD UY, the 
defendants, and others known and unknown, willfully and 
knowingly would and did transport, transmit, and transfer, and 
-54 -

attempt to transport, transmit, and transfer a monetary 
instrument and funds from a place in the United States to and 
through a place outside the United States and to a place in the 
United States from and through a place outside the United States 
with the intent to promote the carrying on of a specified 
unlawful activity, to wit, an illegal gambling business in 
violation of Title 18, United States Code, Sections 1955 and 
1084, and New York Penal Law Section 225.10, all in violation of 
Title 18, United States Code, Section 1956 (a) (2) (A). 
67. It was further a part and an object of the 
conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, 
NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON 
MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER 
SKYLLAS, and RONALD UY, the defendants, and others known and 
unknown, in an offense involving and affecting interstate and 
foreign commerce, would and did engage in and attempt to engage 
in monetary transactions, as that term is defined in Title 18, 
United States Code, Section 1957(f) (1), in criminally derived 
property that was of a value greater than $10,000, to wit, wire 
transfers in excess of $10,000 between various bank accounts 
controlled by the defendants and clients of the illegal gambling 
business, such property having been derived from a specified 
unlawful activity, to wit, an illegal gambling business in 
violation of Title 18, United States Code, Sections 1955 and 
-55 -

1084
1 
and New York Penal Law Section 225.10
1 
all in violation of 
Title 18
1 
United States Coder Section 1957. 
(Title 18
1 
United States Coder Section 1956(h). 
COUNT THIRTEEN 
(Structuring) 
The Grand Jury further charges: 
68. From at least in or about January 2012
1 
up to and 
including on or about the date of this Indictment
1 
in the 
Southern District of New York and elsewhere/ RONALD UY and ILLYA 
TRINCHER
1 
the defendants/ knowingly and willfully/ and for the 
purpose of evading the reporting requirements of Section 5313(a) 
of Title 31
1 
United States Coder and the regulations promulgated 
thereunder/ did structure and assist in structuring/ and 
attempted to structure and assist in structuring/ a transaction 
with one and more domestic financial institutions/ and did aid 
and abet the samer to wit
1 
RONALD UY
1 
a branch manager at a 
JPMorgan Chase Bank located in New York City (the "Bank") r did 
assist TRINCHER in structuring several transactions at the Bank 
designed in part to avoid generating currency transaction 
reports. 
(Title 31
1 
United States Coder Sections 5324 (a) (3) and (d)  (1) 
Title 18
1 
United Stated Coder Section 2.) 
-56 -

COUNT FOURTEEN 
(Extortion of Client-3) 
The Grand Jury further charges: 
69. From at least in or about January 2010, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ILLYA TRINCHER, 
ARTHUR AZEN, DON MCCALMONT, and JOHN HANSON, the defendants, 
willfully and knowingly did participate in the use of 
extortionate means, as that term is defined 1n Title 18, United 
States Code, Section 891(7), to collect and attempt to collect 
extensions of credit, as that term is defined in Title 18, 
United States Code, Section 891(1), and to punish a person, to 
wit, Client-3, for the nonrepayment thereof, to wit, TRINCHER, 
AZEN, MCCALMONT, and HANSON threatened to cause, and did cause, 
harm to Titan, Client-3's plumbing company, to collect and 
attempt to collect a $2,000,000 gambling debt that Client-3 owed 
to the Trincher-Nahmad Organization. 
(Title 18, United States Code, Sections 894(a) (1) and (a) (2) .) 
COUNT FIFTEEN 
(Wire Fraud Conspiracy) 
The Grand Jury further charges: 
70. From at least in or about March 2012, up to and 
including on or about the date of this indictment, in the 
Southern District of New York and elsewhere, HILLEL NAHMAD, 
-57 -

a/k/a "Helly," and NICHOLAS HIRSH, the defendants, and others 
known and unknown, knowingly and willfully did combine, 
conspire, confederate, and agree together and with each other to 
violate Title 18, United States Code, Section 1343. 
71. It was a part and an object of the conspiracy 
that HILLEL NAHMAD, a/k/a "Helly," and NICHOLAS HIRSH, the 
defendants, and others known and unknown, having devised and 
intending to devise any 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 and foreign commerce, a 
writing, sign, signal, picture, and sound for the purpose of 
executing such scheme and artifice, in violation of Title 18, 
United States Code, Section 1343, to wit, HILLEL NAHMAD, a/k/a 
"Helly," and NICHOLAS HIRSCH used interstate and international 
wires in furtherance of a scheme to defraud an individual 
concerning a sale of a piece of art that they claimed to be 
worth approximately $300,000 but was in fact worth at least 
approximately $50,000 less. 
(Title 18, United States Code, Section 1349.) 
-58 -

COUNT SIXTEEN 
(Illegal Sports Gambling Business: Druzhinsky Organization) 
The Grand Jury further charges: 
72. From at least in or about 2008~ up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, DMITRY DRUZHINSKY, 
ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a 
"Murashka," and ARTHUR AZEN, the defendants, knowingly and 
willfully did conduct, finance, manage, supervise, direct, and 
own all and part of an illegal gambling business, as that term 
is defined in Title 18, United States Code, Section 1955 (b) (1), 
(2), and (3), to wit, DRUZHINSKY, ZAVERUKHA, KATCHALOFF, and 
AZEN operated a bookmaking business that violated New York Penal 
Law Section 225.10, involved five or more persons who conducted, 
financed, managed, supervised, directed, and owned all or part 
of such business, and had been and remained in substantially 
continuous operation for a period in excess of thirty days and 
had a gross revenue of $2,000 in any single day. 
(Title 18, United States Code, Sections 1955 and 2.) 
-59 -

COUNT SEVENTEEN 
(Acceptance of Financial Instrument 
for Unlawful Internet Sports Gambling) 
The Grand Jury further charges: 
73. From at least in or about 2008, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, DMITRY DRUZHINSKY, 
ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a 
"Murashka," and ARTHUR AZEN, the defendants, who were engaged in 
the business of betting and wagering, knowingly and willfully 
did accept, in connection with the participation of another 
person in unlawful Internet gambling, credit, and the proceeds 
of credit, extended to and on behalf of such other person 
(including credit extended through the use of a credit card); an 
electronic fund transfer, and funds transmitted by and through a 
money transmitting business, and the proceeds of an electronic 
fund transfer and money transmitting service, from and on behalf 
of such other person; a check, draft, and similar instrument 
which was drawn by and on behalf of such other person and was 
drawn on and payable at and through a financial institution; and 
the proceeds of another form of financial transaction, as the 
Secretary and the Board of Governors of the Federal Reserve 
System have prescribed by regulation, which involves a financial 
institution as a payor and financial intermediary on behalf of 
-60 -

and for the benefit of such other person, to wit, DRUZHINSKY, 
ZAVERUKHA, KATCHALOFF and AZEN, operated an illegal bookmaking 
business that utilized gambling websites operating illegally in 
the United States. 
(Title 31, United States Code, Sections 5363 and 5366; 
Title 18, United States Code, Section 2.) 
COUNT EIGHTEEN 
(Money Laundering Conspiracy) 
The Grand Jury further charges: 
74. From at least in or about 2008, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, DMITRY DRUZHINKSKY, 
ANATOLY GOLUBCHIK, a/k/a "Tony," ILYA ROZENFELD, and ANATOLY 
SHTEYNGRAB, the defendants, and others known and unknown, 
willfully and knowingly combined, conspired, confederated, and 
agreed together and with each other to violate Sections 1956 
(a) ( 1 ) (B) ( i  )  , (a) ( 2 ) (A) , and (a) ( 2 ) (B) ( i  )  , and 19 57 of Title 18 , 
United States Code, to wit, the defendants laundered millions of 
dollars in p~oceeds from DRUZHINSKY's sports gambling business 
through various companies including a real estate company in New 
York, New York, a car repair shop in Brooklyn, New York, and a 
company that sells used cars over the internet. 
75. It was a part and an object of the conspiracy 
that DMITRY DRUZHINKSKY, ANATOLY GOLUBCHIK, a/k/a "Tony," ILYA 
-61 -

ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, and others 
known and unknown, knowing that the property involved in such 
financial transactions represented the proceeds of some form of 
unlawful activity, willfully and knowingly would and did conduct 
and attempt to conduct financial transactions which in fact 
involved the proceeds of specified unlawful activity, to wit, an 
illegal gambling business in violation of Title 18, United 
States Code, Sections 1955 and 1084, and New York Penal Law 
Section 225.10, knowing that such financial transactions were 
designed in whole and in part to conceal and disguise the 
nature, location, source, ownership and control of the proceeds 
of specified unlawful activity, in violation of Title 18, United 
States Code, Section 1956 (a) (1) (B) (i). 
76. It was further a part and an object of the 
conspiracy that DMITRY DRUZHINKSKY, ANATOLY GOLUBCHIK, a/k/a 
"Tony," ILYA ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, 
and others known and unknown, willfully and knowingly would and 
did transport, transmit, and transfer, and attempt to transport, 
transmit, and transfer a monetary instrument and funds from a 
place in the United States to and through a place outside the 
United States and to a place in the United States from and 
through a place outside the United States with the intent to 
promote the carrying on of a specified unlawful activity, to 
wit, an illegal gambling business in violation of Title 18, 
-62 -

United States Code
1 
Sections 1955 and 1084/ and New York Penal 
Law Section 225.10
1 
all in violation of Title 18
1 
United States 
Code
1 
Section 1956 (a) (2) (A). 
77. It was further a part and an object of the 
conspiracy that DMITRY DRUZHINKSKY
1 
ANATOLY GOLUBCHIK
1 
a/k/a 
"Tony
1
11 
ILYA ROZENFELD
1 
and ANATOLY SHTEYNGRAB
1 
the defendants/ 
and others known and unknown/ willfully and knowingly would and 
did transport/ transmit/ and transfer/ and attempt to transport/ 
transmit/ and transfer monetary instruments and funds from a 
place in the United States to and through a place outside the 
United States and to a place in the United States from and 
through a place outside the United States knowing that the 
monetary instruments and funds involved in the transportations/ 
transmissions/ and transfers represented the proceeds of some 
form of unlawful activity and knowing that such transportations/ 
transmissions/ and transfers were designed in whole and in part 
to conceal and disguise the nature/ the location/ the source/ 
the ownership/ and the control of the proceeds of a specified 
unlawful activity/ to wit
1 
an illegal gambling business in 
violation of Title 18
1 
United States Code/ Sections 1955 and 
1084
1 
and New York Penal Law Section 225.10
1 
all in violation of 
Title 18
1 
United States Code/ Section 1956 (a) (2) (B) (i). 
78. It was further a part and an object of the 
conspiracy that DMITRY DRUZHINKSKY
1 
ANATOLY GOLUBCHIK
1 
a/k/a 
-63 -

"Tony," ILYA ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, 
and others known and unknown, in an offense involving and 
affecting interstate and foreign commerce, would and did engage 
in and attempt to engage in monetary transactions, as that term 
is defined in Title 18, United States Code, Section 1957(f) (1), 
in criminally derived property that was of a value greater than 
$10,000, to wit, wire transfers in excess of $10,000 between 
bank accounts in Cyprus controlled by the defendants and bank 
accounts in the United States controlled by the defendants, such 
property having been derived from a specified unlawful activity, 
to wit, an illegal gambling business in violation of Title 18, 
United States Code, Sections 1955 and 1084, and New York Penal 
Law Section 225.10, all in violation of Title 18, United States 
Code, Section 1957. 
(Title 18, United States Code, Section 1956(h) .) 
COUNT NINETEEN 
(To 
Collect Extensions of Credit by Extortionate Means) 
The Grand Jury further charges: 
79. From at least in or about January 2012, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, ARTHUR AZEN, KIRILL 
RAPOPORT, and MOSHE ORATZ, the defendants, and others known and 
unknown, knowingly and willfully combined, conspired, 
-64 -

confederated, and agreed together and with each other to 
participate in the use of extortionate means, as that term is 
defined in Title 18, United States Code, Section 891(7), to 
collect and attempt to collect extensions of credit, as that 
term is defined in Title 18, United States Code, Section 891(1), 
and to punish a person, to wit, gamblers who owed poker and/or 
sports gambling debts, for the nonrepayment thereof, to wit, 
AZEN, RAPOPORT, and ORATZ, agreed to use violence and threats of 
violence to collect sports and poker gambling debts from 
gamblers. 
(Title 18, United States Code, Section 894.) 
COUNT TWENTY 
(Illegal Poker Business) 
The Grand Jury further charges: 
80. From at least in or about 2010, up to and 
including on or about the date of this Indictment, in the 
Southern District of New York and elsewhere, EUGENE TRINCHER, 
EDWIN TING, a/k/a "Eddie," ARTHUR AZEN, JOSEPH MANCUSO, WILLIAM 
BARBALAT, YUGESHWAR RAJKUMAR, a/k/a "Mateo Hermatte," MOLLY 
BLOOM, the defendants, knowingly and willfully did conduct, 
finance, manage, supervise, direct, and own all and part of an 
illegal gambling business, as that term is defined in Title 18, 
United States Code, Section 1955 (b) (1), (2), and (3), and did 
-65 -

aid and abet the same, to wit, TRINCHER, TING, AZEN, MANCUSO, 
BARBALAT, RAJKUMAR, and BLOOM, operated an illegal poker 
business which violated New York Penal Law Section 225.05, 
involved five or more persons who conducted, financed, managed, 
supervised, directed, and owned all or part of such business, 
and had been and remained in substantially continuous operation 
for a period in excess of thirty days and had a gross revenue of 
$2,000 in any single day. 
(Title 18, United States Code, Sections 1955 and 2.) 
COUNT TWENTY-ONE 
(Travel Act) 
The Grand Jury further charges: 
81. In or about December 2011, in the Southern 
District of New York and elsewhere, EUGENE TRINCHER, the 
defendant, intentionally and knowingly did travel in interstate 
and foreign commerce and use the mail and a facility in 
interstate and foreign commerce, with intent to distribute the 
proceeds of an unlawful activity, and to otherwise promote, 
manage, establish, carry on, and facilitate the promotion, 
management, establishment, and carrying on, of an unlawful 
activity, and thereafter did distribute and attempt to 
distribute the proceeds of an unlawful activity, and to 
otherwise promote, manage, establish, carry on, and facilitate 
-66 -

the promotion, management, establishment, and carrying on, of an 
unlawful activity, to wit, TRINCHER caused a check in the amount 
of $10,000, issued in connection with operating an illegal poker 
game in New York City, to be deposited into a bank account in 
Connecticut. 
(Title 18, United States Code, Sections 1952 and 2.) 
COUNT TWENTY-TWO 
(Travel Act) 
The Grand Jury further charges: 
82. In or about November 2011, in the Southern 
District of New York and elsewhere, EDWIN TING, a/k/a "Eddie," 
the defendant, intentionally and knowingly did travel in 
interstate and foreign commerce and use the mail and a facility 
in interstate and foreign commerce, with intent to distribute 
the proceeds of an unlawful activity, and to otherwise promote, 
manage, establish, carry on, and facilitate the promotion, 
management, establishment, and carrying on, of an unlawful 
activity, and thereafter did distribute and attempt to 
distribute the proceeds of an unlawful activity, and to 
otherwise promote, manage, establish, carry on, and facilitate 
the promotion, management, establishment, and carrying on, of an 
unlawful activity, to wit, TING, deposited a check in the amount 
of $250,000 from a bank account in California into a bank 
-67 -

account in New York, in connection with operating an illegal 
poker game in New York City. 
(Title 18, United States Code, Sections 1952 and 2.) 
COUNT TWENTY-THREE 
(Travel Act) 
The Grand Jury further charges: 
83. In or about March 2011, in the Southern District 
of New York and elsewhere, ARTHUR AZEN, the defendant, 
intentionally and knowingly did travel in interstate and foreign 
commerce and use the mail and a facility in interstate and 
foreign commerce, with intent to distribute the proceeds of an 
unlawful activity, and to otherwise promote, manage, establish, 
carry on, and facilitate the promotion, management, 
establishment, and carrying on, of an unlawful activity, and 
thereafter did distribute and attempt to distribute the proceeds 
of an unlawful activity, and to otherwise promote, manage, 
establish, carry on, and facilitate the promotion, management, 
establishment, and carrying on, of an unlawful activity, to wit, 
AZEN deposited a check from WILLIAM BARBALAT, the defendant, in 
the amount of $4,000 in a connection with operating an illegal 
-68 -

poker game in New York City, which check cleared by interstate 
wire. 
(Title 18, United States Code, Sections 1952 and 2.) 
COUNT TWENTY-FOUR 
(Travel Act) 
The Grand Jury further charges: 
84. In or about February 2012, in the Southern 
District of New York and elsewhere, JOSEPH MANCUSO, the 
defendant, intentionally and knowingly did travel in interstate 
and foreign commerce and use the mail and a facility in 
interstate and foreign commerce, with intent to distribute the 
proceeds of an unlawful activity, and to otherwise promote, 
manage, establish, carry on, and facilitate the promotion, 
management, establishment, and carrying on, of an unlawful 
activity, and thereafter did distribute and attempt to 
distribute the proceeds of an unlawful activity, and to 
otherwise promote, manage, establish, carry on, and facilitate 
the promotion, management, establishment, and carrying on, of an 
unlawful activity, to wit, MANCUSO wrote a check in the amount 
of $30,000 in connection with operating an illegal poker game in 
New York City, which check was deposited into a bank account in 
Connecticut. 
(Title 18, United States Code, Sections 1952 and 2.) 
-69 -

COUNT TWENTY-FIVE 
(Travel Act) 
The Grand Jury further charges: 
85. In or about March 2011, in the Southern District 
of New York and elsewhere, WILLIAM BARBALAT, the defendant, 
intentionally and knowingly did travel in interstate and foreign 
commerce and use the mail and a facility in interstate and 
foreign commerce, with intent to distribute the proceeds of an 
unlawful activity, and to otherwise promote, manage, establish, 
carry on, and facilitate the promotion, management, 
establishment, and carrying on, of an unlawful activity, and 
thereafter did distribute and attempt to distribute the proceeds 
of an unlawful activity, and to otherwise promote, manage, 
establish, carry on, and facilitate the promotion, management, 
establishment, and carrying on, of an unlawful activity, to wit, 
BARBALAT wrote a check to ARTHUR AZEN, the defendant, in the 
amount of $4,000 in a connection with operating an illegal poker 
game in New York City, which check cleared by interstate wire. 
(Title 18, United States Code, Sections 1952 and 2.) 
-70 -

COUNT TWENTY-SIX 
(Travel Act) 
The Grand Jury further charges: 
86. In or about January 2011, in the Southern 
District of New York and elsewhere, YUGESHWAR RAJKUMAR, a/k/a 
"Mateo Hermatte," the defendant, intentionally and knowingly did 
travel in interstate and foreign commerce and use the mail and a 
facility in interstate and foreign commerce, with intent to 
distribute the proceeds of an unlawful activity, and to 
otherwise promote, manage, establish, carry on, and facilitate 
the promotion, management, establishment, and carrying on, of an 
unlawful activity, and thereafter did distribute and attempt to 
distribute the proceeds of an unlawful activity, and to 
otherwise promote, manage, establish, carry on, and facilitate 
the promotion, management, establishment, and carrying on, of an 
unlawful activity, to wit, RAJKUMAR wrote a check from his New 
Jersey bank account in the amount of $11,500 in connection with 
operating an illegal poker game in New York City. 
(Title 18, United States Code, Sections 1952 and 2.) 
-71 -

COUNT TWENTY-SEVEN 
(Travel Act) 
The Grand Jury further charges: 
87. In or about June 2010, in the Southern District 
of New York and elsewhere, MOLLY BLOOM, the defendant, 
intentionally and knowingly did travel in interstate and foreign 
commerce and use the mail and a facility in interstate and 
foreign commerce, with intent to distribute the proceeds of an 
unlawful activity, and to otherwise promote, manage, establish, 
carry on/ and facilitate the promotion, management, 
establishment, and carrying on, of an unlawful activity, and 
thereafter did distribute and attempt to distribute the proceeds 
of an unlawful activity, and to otherwise promote, manage, 
establish, carry on/ and facilitate the promotion, management, 
establishment, and carrying on, of an unlawful activity, to wit, 
BLOOM deposited two checks totally $25,900 into a bank account 
in California in connection with operating an illegal poker game 
in New York City. 
(Title 18, United States Code, Sections 1952 and 2.) 
-72 -

Forfeiture Allegation as to Counts One and Two 
(Taiwanchik-Trincher Organization) 
88. The allegations contained in Counts One and Two 
of this Indictment are hereby repeated, realleged, and 
incorporated by reference herein as though fully set forth at 
length for the purpose of alleging forfeiture pursuant to Title 
18, United States Code, Section 2461(c). 
89. Pursuant to Rule 32.2(a), Fed. R. Crim. P., 
ALIMZHAN TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM TRINCHER, 
a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and 
STAN GREENBERG, a/k/a "Slava," the defendants, are hereby 
notified that, upon conviction of the violation or violations of 
Title 18, United States Code, Section 1962, in Counts One and 
Two the Indictment, the defendants shall forfeit, pursuant to 
Title 18, United States Code, Section 1963: 
a. all interests acquired and maintained in 
violation of Title 18, United States Code, Section 1962i 
b. all interests in, securities of, claims 
against, and property and contractual rights of any kind 
affording a source of influence over, the enterprise named and 
described herein which the defendants established, operated, 
controlled, conducted, and participated in the conduct of, in 
violation of Title 18, United States Code, Section 1962i and 
-73 -

c. all property constituting and derived from 
proceeds obtained, directly and indirectly, from racketeering 
activity in violation of Title 18, United States Code, Section 
1962. 
90. The property subject to forfeiture to the United 
States pursuant to Title 18, United States Code, Section 
1963 (a) (1), (a) (2), and (a) (3), includes, but is not limited at 
least $50 million which represents the total of the interests 
acquired and the gross proceeds obtained through the violation 
of Title 18, United States Code, Section 1962, and the following 
specific property which constitutes and is derived from proceeds 
obtained, directly and indirectly, from racketeering activity in 
violation of Title 18, United States Code, Section 1962: 
a. 721-725 5th Avenue, Apartment 63A and B, New 
York, NY 10022; 
b. 971 Madison Avenue, Units SA, B and C, New 
York, NY 10021; 
c. 16001 Collins Avenue, Unit 806, Sunny Isles 
Beach, FL 33160; and 
d. 16001 Collins Avenue, Unit 1206, Sunny Isles 
Beach, FL 33160. 
91. Pursuant to Title 18, United States Code, Section 
1963(m), ALIMZHAN TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM 
TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL 
-74 -

SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, shall 
forfeit substitute property up to the value of the property 
described in the previous paragraph if that property, as a 
result of any act or omission of the defendants: 
a. cannot be located upon the exercise of due 
diligence; 
b. has been transferred or sold to, or 
deposited with, a third party; 
c. has been placed beyond the jurisdiction of 
this Court; 
d. has been substantially diminished in value; 
and 
e. has been commingled with other property 
which cannot be divided without difficulty. 
92. The above-named defendants are jointly and 
severally liable for the forfeiture allegations alleged above. 
(Title 18, United States Code, Section 1963.) 
Forfeiture Allegation as to Counts Three and Four 
(Nahmad-Trincher Organization) 
93. The allegations contained in Counts Three and 
Four of this Indictment are hereby repeated, realleged, and 
incorporated by reference herein as though fully set forth at 
-75 -

length for the purpose of alleging forfeiture pursuant to Title 
18, United States Code, Section 2461(c). 
94. Pursuant to Rule 32.2(a), Fed. R. Crim. P., ILLYA 
TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 
Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD 
MCCALMONT, the defendants, are hereby notified that, upon 
conviction of the violation or violations of Title 18, United 
States Code, Section 1962, as charged in Counts Three and Four 
of this Indictment, the defendants shall forfeit, pursuant to 
Title 18, United States Code, Section 1963: 
a. all interests acquired and maintained in 
violation of Title 18, United States Code, Section 1962; 
b. all interests in, securities of, claims 
against, and property and contractual rights of any kind 
affording a source of influence over, the enterprise named and 
described herein which the defendants established, operated, 
controlled, conducted, and participated in the conduct of, in 
violation of Title 18, United States Code, Section 1962; and 
c. all property constituting and derived from 
proceeds obtained, directly and indirectly, from racketeering 
activity in violation of Title 18, United States Code, Section 
1962. 
95. The property subject to forfeiture to the United 
States pursuant to Title 18, United States Code, Section 
-76 -

1963 (a) (1) r (a) (2) r and (a) (3) r includes/ but is not limited at 
least $50 million which represents the total of the interests 
acquired and the gross proceeds obtained through the violation 
of Title 18
1 
United States Coder Section 1962
1 
which constitutes 
and is derived from proceeds obtained/ directly and indirectly/ 
from racketeering activity in violation of Title 18r United 
States Coder Section 1962. 
96. Pursuant to Title 18
1 
United States Coder Section 
1963(m) 
1 
ILLYA TRINCHER
1 
HILLEL NAHMAD
1 
a/k/a "Helly
1
11 
NOAH 
SIEGEL
1 
a/k/a "The Oracle
1
11 
JOHN HANSON
1 
JONATHAN HIRSCH
1 
ARTHUR 
AZEN
1 
and DONALD MCCALMONT
1 
the defendants/ shall forfeit 
substitute property up to the value of the property described in 
the previous paragraph if that property/ as a result of any act 
or omission of the defendants: 
a. cannot be located upon the exercise of due 
diligence; 
b. has been transferred or sold tor or 
deposited with/ a third party; 
c. has been placed beyond the jurisdiction of 
this Court; 
d. has been substantially diminished in value; 
and 
e. has been commingled with other property 
which cannot be divided without difficulty. 
-77 -

97. The above-named defendants are jointly and 
severally liable for the forfeiture allegations alleged above. 
(Title 18, United States Code, Section 1963.) 
Forfeiture Allegation as to Counts Five, Eight, Nine, Ten, 
Fourteen, Fifteen, Sixteen, and Nineteen to Twenty-Seven 
98. As a result of committing the illegal gambling 
business, extortion, transmission of sports wagering 
information, travel act, and wire fraud offenses alleged in 
Counts Five, Eight, Nine, Ten, Fourteen, Fifteen, Sixteen, and 
Nineteen to Twenty-Seven of this Indictment, ALIMZHAN 
TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 
a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," HILLEL 
NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The 
Oracle," JOHN HANSON, JONATHAN HIRSCH, JUSTIN SMITH, WILLIAM 
EDLER, PETER FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a "D.A. ," 
BRYAN ZURIFF, ABRAHAM MOSSERI, DMITRY DRUZHINSKY, ALEXANDER 
ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a 
"Murashka," ARTHUR AZEN, KIRILL RAPOPORT, MOSHE ORATZ, EUGENE 
TRINCHER, EDWIN TING, a/k/a "Eddie," JOSEPH MANCUSO, WILLIAM 
BARBALAT, YUGESHWAR RAJKUMAR, a/k/a "Mateo Hermatte," MOLLY 
BLOOM, the defendants, shall forfeit to the United States 
pursuant to Title 18, United States Code, Section 981(a) (1) (C) 
and Title 28, United States Code, S.ection 2461, any and all 
-78 -

property constituting, and derived from, proceeds obtained 
directly and indirectly as a result of such violations. 
99. As a result of the illegal gambling business 
offenses alleged in Counts Five, Nine, Sixteen and Twenty of 
this Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 
a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY 
GOLUBCHIK, a/k/a "Tony," HILLEL NAHMAD, a/k/a "Helly," ILLYA 
TRINCHER, 
NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN 
HIRSCH, JUSTIN SMITH, WILLIAM EDLER, PETER FELDMAN, MOSHE ORATZ, 
DAVID AARON, a/k/a "D.A.," BRYAN ZURIFF, ABRAHAM MOSSERI, DMITRY 
DRUZHINSKY, ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER 
KATCHALOFF, a/k/a "Murashka," ARTHUR AZEN, KIRILL RAPOPORT, 
MOSHE ORATZ, EUGENE TRINCHER, EDWIN TING, a/k/a "Eddie," JOSEPH 
MANCUSO, WILLIAM BARBALAT, YUGESHWAR RAJKUMAR, a/k/a "Mateo 
Hermatte," MOLLY BLOOM, the defendants, shall forfeit to the 
United States pursuant to Title 18, United States Code, Section 
1955(d), any property, including money, used in such violations. 
Substitute Asset Provision 
100. If any of the above-described forfeitable 
property, as a result of any act or omission of the defendants: 
a. cannot be located upon the exercise of due 
diligence; 
b. has been transferred or sold to, or 
deposited with, a third person; 
-79 -

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 (p), to seek forfeiture of any 
other property of said defendants up to the value of the above-
described forfeitable property. 
(Title 18, United States Code, Section 981 and 1955; 
Title 21, United States Code, Section 853; 
and Title 28, United States Code, Section 2461.) 
Forfeiture Allegation as to Counts Seven, Twelve, and Eighteen 
101. As a result of committing the money laundering 
offenses alleged in Counts Seven, Twelve, Eighteen of this 
Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 
"Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, 
a/k/a "Tony," HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH 
SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, DMITRY 
DRUZHINSKY, ALEXANDER ZAVERUKHA, a/k/a "Sasha," EUGENE TRINCHER, 
EDWIN TING, a/k/a "Eddie," PETER SKYLLAS, RONALD UY, DON 
MCCALMONT, ILYA ROSENFELD, and ANATOLY SHTEYNGRAB, the 
defendants, shall forfeit to the United States pursuant to Title 
-80 -

18, United States Code, Section 982(a) (1), any property, real or 
personal, involved in such offense, or any property traceable to 
such property. 
Substitute Asset Provision 
102. If any of the above-described forfeitable 
property, as a result of any act or omission of the defendants: 
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(p), to seek forfeiture of any 
other property of said defendants up to the value of the above-
described forfeitable property. 
(Title 18, United States Code, Section 982; 
and Title 21, United States Code, Section 853.) 
Forfeiture Allegation as to Count Thirteen 
-81 -

103. As a result of committing the structuring offense 
alleged in Count Thirteen of this Indictment, RONALD UY and 
ILLYA TRINCHER, the defendants, shall forfeit to the United 
States pursuant to Title 31, United States Code, Section 
5317(c), all property, real or personal, involved in such 
offense, or any property traceable to such property. 
Substitute Asset Provision 
104. If any of the above-described forfeitable 
property, as a result of any act or omission of the defendants: 
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(p), to seek forfeiture of any 
-82 -

other property of said defendants up to the value of the above-
described forfeitable property. 
(31, United States Code, Section 5317(c); and 
Title 21, United States Code, Section 853.) 
PREET BHARARA 
United States Attorney 
-83 -

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
-v. -
ALIMZHAN TOKHTAKHOUNOV, a/k/a 
"Taiwanchik," a/k/a "Alik," VADIM 
TRINCHER, a/k/a "Dima," ANATOLY 
GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, 
STAN GREENBERG, a/k/a "Slava," ILLYA 
TRINCHER, HILLEL 
NAHMAD, a/k/a "Helly," 
JOHN HANSON, NOAH SIEGEL, a/k/a "The 
Oracle," JONATHAN HIRSCH, ARTHUR AZEN, 
DONALD MCCALMONT, DMITRY DRUZHINSKY, 
a/k/a "Dima," a/k/a "Blondie," ALEXANDER 
ZAVERUKHA, a/k/a "Sasha," ALEXANDER 
KATCHALOFF, a/k/a "Murushka," ANATOLY 
SHTEYNGROB, a/k/a "Tony," ILYA 
ROZENFELD, PETER 
SKYLLAS, RONALD UY, 
NICHOLAS HIRSCH, BRYAN ZURIFF, MOSHE 
ORATZ, KIRILL RAPOPORT, DAVID AARON, 
a/k/a "D.A.," JUSTIN SMITH, ABRAHAM 
MOSSERI, WILLIAM EDLER, PETER FELDMAN, 
EUGENE TRINCHER, EDWIN TING, a/k/a 
"Eddie," MOLLY BLOOM, WILLIAM BARBALAT, 
YUGESHWAR RAJKUMAR, a/k/a "Mateo 
Hermatte," and JOSEPH MANCUSO,a/k/a "Joe 
the Hammer," 
Defendants. 
SEALED INDICTMENT 
13 Cr. 
(18 u.s.c. §§ 894, 1084, 1951,   1952, 
1955, 1956, 1962, and 2; 
31 U.S.C. §§ 5324, 5363, and 5366.) 
PREET BHARARA 
United States A~torney. 
/ 
son. 

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 

- v. -

ALIMZHAN TOKHTAKHOUNOV, 
a/k/a "Taiwanchik," 
a/k/a "Alik," 

VADIM TRINCHER, 
a/k/a "Dima," 

ANATOLY GOLUBCHIK, 
a/k/a "Tony," 

MICHAEL SALL, 
STAN GREENBERG, 

a/k/a "Slava," 
ILLYA TRINCHER, 
HILLEL NAHMAD, 

a/k/a "Helly," 
JOHN HANSON, 
NOAH SIEGEL, 

a/k/a "The Oracle," 
JONATHAN HIRSCH, 
ARTHUR AZEN, 
DONALD MCCALMONT, 
DMITRY DRUZHINSKY, 

a/k/a "Dima," 
a/k/a "Blondie," 

ALEXANDER ZAVERUKHA, 
a/k/a "Sasha," 

ALEXANDER KATCHALOFF, 
a/k/a "Murushka," 

ANATOLY SHTEYNGROB, 
a/k/a "Tony," 

ILYA ROZENFELD, 
PETER SKYLLAS, 
RONALD UY, 
NICHOLAS HIRSCH, 
BRYAN ZURIFF, 
MOSHE ORATZ, 
KIRILL RAPOPORT, 
DAVID AARON, 

a/k/a "D.A.," 
JUSTIN SMITH, 
ABRAHAM MOSSERI, 

-X 

- 1 -

SEALED 
INDICTMENT 

13 Cr. 



WILLIAM EDLER, 
PETER FELDMAN, 
EUGENE TRINCHER, 
EDWIN TING, 

a/k/a "Eddie," 
MOLLY BLOOM, 
WILLIAM BARBALAT, 
YUGESHWAR RAJKUMAR, 

a/k/a "Mateo Hermatte," and 
JOSEPH MANCUSO, 

a/k/a "Joe the Hammer," 

Defendants. 

- - - - - - - - - - - - - - - - - -x 

COUNT ONE 

(Racketeering Conspiracy: Taiwanchik-Trincher Organization) 

The Grand Jury charges: 

The Enterprise 

1. At all times relevant to this Indictment, 

ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM 

TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL 

SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, and 

others known and unknown, were members and associates of the 

"Taiwanchik-Trincher Organization." The Taiwanchik-Trincher 

Organization was a criminal organization whose members and 

associates engaged in crimes including operating an illegal 

gambling business, money laundering, and extortion. 

2. The Taiwanchik-Trincher Organization, including 

its leadership, membership, and associates, constituted an 

- 2 -



"enterprise," as that term is defined in Title 18, United States 

Code, Section 1961(4) -- that is, a group of individuals 

associated in fact. This enterprise was engaged in, and its 

activities affected, interstate and foreign commerce. The 

Taiwanchik-Trincher Organization was an international organized 

crime group with leadership based in New York City, Kiev, and 

Moscow, and that operated throughout the United States, 

including in the Southern District of New York, and 

internationally. The Taiwanchik-Trincher Organization 

constituted an ongoing organization whose members functioned as 

a continuing unit for a common purpose of achieving the 

objectives of the enterprise. 

3. Most members and associates of the Taiwanchik­

Trincher Organization were born in the former Soviet Union and 

many maintained substantial ties to Ukraine and the Russian 

Federation, including regular travel to Ukraine and the Russian 

Federation, criminal connections to individuals residing in 

Ukraine and the Russian Federation, the transfer of criminal 

proceeds to and from Ukraine and the Russian Federation, the 

purchase of real estate and other assets in Ukraine and the 

Russian Federation with criminal proceeds, and the operation of 

an international gambling business in Ukraine and the former 

Soviet Union. 

- 3 -



4. The Taiwanchik-Trincher Organization was led 

principally by three individuals: ALIMZHAN TOKHTAKHOUNOV, a/k/a 

"Taiwanchik," a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and 

ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants. 

5. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 

"Alik," the defendant, who lived in the Russia Federation, was a 

"vory v zakone," commonly referred to as "Vor" -- a Russian term 

translated as "Thief-in-Law" and referring to a member of a 

select group of the highest-level criminal figures from the 

former Soviet Union who receives tribute from other criminals, 

offers protection, and uses his recognized position of authority 

to resolve disputes among criminals. As a Vor, TOKHTAKHOUNOV 

had substantial influence in the criminal underworld and offered 

assistance to and protection of the Taiwanchik-Trincher 

Organization. 

6. The two other leaders of the Taiwanchik-Trincher 

Organization, VADIM TRINCHER, a/k/a "Dima," and ANATOLY 

GOLUBCHIK, a/k/a "Tony," the defendants, were based in New York 

City. TRINCHER and GOLUBCHIK were the principal, though not 

exclusive, leaders of the Taiwanchik-Trincher Organization's 

criminal conduct and ventures, which included an illegal 

gambling business, money laundering, extortion, and other 

crimes. TRINCHER and GOLUBCHIK were assisted by numerous 

- 4 -



criminal partners and associates throughout the United States, 

Ukraine, the Russian Federation, and elsewhere. 

The Defendants 

7. Vor ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 

a/k/a "Alik," the defendant, was a powerful figure in former 

Soviet Union organized crime. TOKHTAKHOUNOV rarely left the 

former Soviet Union because he was under indictment by the 

United States Attorney's Office for the Southern District of New 

York on charges related to his role in allegedly bribing 

officials at the 2002 Winter Olympic Games in Salt Lake City, 

Utah. TOKHTAKHOUNOV was a participant in the enterprise, the 

Taiwanchik-Trincher Organization, and was a leader of it. 

TOKHTAKOUNOV used his status as a Vor to resolve disputes with 

clients of the high-stakes illegal gambling operation with 

implicit and sometimes explicit threats of violence and economic 

harm. From in or around December 2011 through in or about 

January 2012, TOKHTAKOUNOV was paid $10,000,000 by the 

Taiwanchik-Trincher Organization. 

8. VADIM TRINCHER, a/k/a "Dima," the defendant, was 

a participant in the enterprise, the Taiwanchik-Trincher 

Organization, and was a leader of it. In that capacity, 

TRINCHER participated in and profited from various crimes, which 

he committed along with other members and associates of the 

Taiwanchik-Trincher Organization. Among other things, TRINCHER 

- 5 -



oversaw a high-stakes illegal sports gambling business that 

catered almost exclusively to oligarchs living in Ukraine and 

the Russian Federation. 

9. ANATOLY GOLUBCHIK, a/k/a "Tony," the defendant, 

was a participant in the enterprise, the Taiwanchik-Trincher 

Organization, and was a leader of the enterprise. In that 

capacity, GOLUBCHIK participated in and profited from various 

crimes, which he committed along with other members and 

associates of the Taiwanchik-Trincher Organization. Among other 

things, GOLUBCHIK worked with TRINCHER to oversee the sports 

gambling business and directed members and associates of the 

Taiwanchik-Trincher Organization in laundering tens of millions 

of dollars of profits from that business. 

10. MICHAEL SALL and STAN GREENBERG, a/k/a "Slava," 

the defendants, were United States-based participants in the 

enterprise, the Taiwanchik-Trincher Organization. In this 

capacity, these defendants participated in and profited from 

various crimes, including money laundering, which they committed 

along with other members and associates of the Taiwanchik­

Trincher Organization. 

Purposes of the Enterprise 

11. The purposes of the enterprise included the 

following: 

- 6 -



a. enriching the leaders, members, and 

associates of the enterprise through an illegal gambling 

business, money laundering, extortion, and other crimes; 

b. preserving and augmenting the power, 

territory, and financial profits of the enterprise through 

intimidation, violence, and threats of physical and economic 

harm; and 

c. avoiding detection of their illegal conduct 

in order to continue to enrich themselves. 

Means and Methods of the Enterprise 

12. Among the means and methods by which ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and 

STAN GREENBERG, a/k/a "Slava," the defendants, and their co­

conspirators, and other members and associates conducted and 

participated in the conduct of the affairs of the Taiwanchik­

Trincher Organization were the following: 

a. Members and associates of the Taiwanchik­

Trincher Organization and their co-conspirators worked together 

on a range of criminal money-making schemes, including operating 

an international gambling business that catered to oligarchs 

residing in the former Soviet Union and throughout the world. 

- 7 -



b. Members and associates of the Taiwanchik­

Trincher Organization and their co-conspirators used threats of 

violence to obtain unpaid gambling debts from clients. 

c. Members and associates of the Taiwanchik­

Trincher Organization and their co-conspirators employed a 

sophisticated money laundering scheme to move tens of millions 

of dollars in proceeds from the gambling operation from the 

former Soviet Union through shell companies in Cyprus into 

various investments and other shell companies in the United 

States. 

The Racketeering Conspiracy 

13. From at least in or about 2006, up to and 

including on or about the date of this Indictment, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and 

STAN GREENBERG, a/k/a "Slava," the defendants, and others known 

and unknown, in the Southern District of New York and elsewhere, 

being persons employed by and associated with the racketeering 

enterprise described in paragraphs 1 through 12 above, namely, 

the Taiwanchik-Trincher Organization, which enterprise was 

engaged in, and the activities of which affected, interstate and 

foreign commerce, willfully and knowingly combined, conspired, 

confederated, and agreed together and with each other to violate 

Title 18, United States Code, Section 1962(c), to wit, to 

- 8 -



conduct and participate, directly and indirectly, in the conduct 

of such enterprise's affairs through a pattern of racketeering 

activity, as those terms are defined in Title 18, United States 

Code, Sections 1961(1) and 1961(5), and as set forth below in 

paragraph 14. It was further a part of the conspiracy that the 

defendants agreed that a conspirator would commit at least two 

acts of racketeering activity in the conduct of the affairs of 

the enterprise. 

The Pattern of Racketeering 

14. The pattern of racketeering activity, as defined 

in Title 18, United States Code, Sections 1961(1) and 1961(5), 

through which ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 

"Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a 

"Tony," MICHAEL SALL, and STAN GREENBERG, a/k/a "Slava," the 

defendants, and their co-conspirators agreed to conduct and 

participate in the conduct of the affairs of the enterprise 

consisted of multiple acts indictable under the following 

federal and state statutes: 

a. Title 18, United States Code, Section 1955 

(operating an illegal gambling business) ; 

b. Title 18, United States Code, Section 1951 

(interference with commerce by threats and violence); 

c. Title 18, United States Code, Sections 1956 

and 1957 (money laundering) ; 

- 9 -



d. Title 18, United States Code, Section 1084 

(transmission of wagering information), 

e. Title 18, United States Code, Section 1952 

(interstate and foreign travel and transportation in aid of 

racketeering enterprises); 

f. Title 18, United States Code, Section 894 

(collection of extensions of credit by extortionate means); and 

g. Multiple acts involving gambling, in 

violation of New York Penal Law Section 225.10. 

It was further a part of the conspiracy that the defendants 

agreed that a conspirator would commit at least two acts of 

racketeering activity in the conduct of the affairs of the 

enterprise. 

(Title 18, United States Code, Section 1962(d) .) 

COUNT TWO 

(Racketeering: Taiwanchik-Trincher Organization) 

The Grand Jury further charges: 

15. The allegations contained in paragraphs 1 through 

12 above are hereby repeated, realleged, and incorporated by 

reference herein as though fully set forth at length for the 

purpose of alleging Count Two of this Indictment. 

16. From at least in or about 2006, up to and 

including on or about the date of this Indictment, ALIMZHAN 

- 10 -



TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 

defendants, and others known and unknown, in the Southern 

District of New York and elsewhere, being persons employed by 

and associated with the racketeering enterprise described in 

paragraphs 1 through 12 above, namely, the Taiwanchik-Trincher 

Organization, which enterprise was engaged in, and the 

activities of which affected, interstate and foreign commerce, 

willfully and knowingly did conduct and participate, directly 

and indirectly, in the conduct of such enterprise's affairs 

through a pattern of racketeering activity as set forth below in 

paragraphs 17 through 24. 

The Pattern of Racketeering 

17. The pattern of racketeering activity, as defined 

in Title 18, United States Code, Sections 1961(1) and 1961(5), 

consisted of the following acts: 

Racketeering Act One: Illegal Gambling Business 

18. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 

"Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, 

a/k/a "Tony," the defendants, supervised an international 

bookmaking operation that catered primarily to oligarchs located 

in the former Soviet Union and throughout the world. The 

defendants committed the following acts, any one of which alone 

constitutes the commission of Racketeering Act One: 

- 11 -

I 



a. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 

defendants, knowingly and willfully did conduct, finance, 

manage, supervise, direct, and own all and part of an illegal 

gambling business, as that term is defined in Title 18, United 

States Code, Section 1955 (b) (1), (2), and (3), to wit, the 

defendants operated a bookmaking business that violated New York 

Penal Law 225.10, involved five or more persons who conducted, 

financed, managed, supervised, directed, and owned all or part 

of such business, and had been and remained in substantially 

continuous operation for a period in excess of thirty days and 

had a gross revenue of $2,000 in any single day, in violation of 

Title 18, United States Code, Section 1955(a). 

b. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 

defendants, knowingly and willfully did advance and profit from 

unlawful gambling activity by engaging in bookmaking to the 

extent that they received and accepted in any one day more than 

- 12 -



five bets totaling more than $5,000, in violation of New York 

Penal Law Section 225.10. 

c. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 

defendants, being engaged in the business of betting and 

wagering, knowingly and willfully did use a wire communication 

facility for the transmission in interstate and foreign commerce 

of bets and wagers and information assisting in the placing of 

bets and wagers on sporting events and contests, and for the 

transmission of wire communications which entitled the recipient 

to receive money and credit as a result of bets and wagers, and 

for information assisting in the placing of bets and wagers, in 

violation of Title 18, United States Code, Section 1084. 

Racketeering Act Two: Extortion Conspiracy 

19. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 

"Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, 

a/k/a "Tony," the defendants, committed the following acts, any 

one of which alone constitutes the commission of Racketeering 

Act Two: 

a. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

- 13 -



Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 

defendants, and others known and unknown, willfully and 

knowingly combined, conspired, confederated, and agreed together 

and with each other to commit extortion, as that term is defined 

in Title 18, United States Code, Section 1951 (b) (2), by 

obtaining money and property from and with the consent of 

another person, to wit, clients of their illegal gambling 

business, which consent was and would have been induced by the 

wrongful use of actual and threatened force, violence and fear, 

and thereby would and did obstruct, delay, and affect commerce 

and the movement of articles and commodities in commerce, as 

that term is defined in Title 18, United States Code, Section 

1951(b) (3), in violation of Title 18, United States Code, 

Section 1951. 

b. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 

defendants, and others known and unknown, willfully and 

knowingly combined, conspired, confederated, and agreed together 

and with each other to participate in the use of extortionate 

- 14 -



means, as that term is defined in Title 18, United States Code, 

Section 891(7), to collect and attempt to collect extensions of 

credit, as that term is defined in Title 18, United States Code, 

Section 891(1), and to punish persons, to wit, clients of their 

illegal gambling business, for the nonrepayment thereof, in 

violation of Title 18, United States Code, Section 894. 

Racketeering Act Three: Extortion of Client-1 

20. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 

"Alik," the defendant, committed the following acts, any one of 

which alone constitutes the commission of Racketeering Act 

Three: 

a. In or about May 2012, in the Southern 

District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, 

a/k/a "Taiwanchik," a/k/a "Alik," the defendant, and others 

known and unknown, willfully and knowingly did commit and 

attempt to commit extortion, and aid and abet the commission of 

extortion, as that term is defined in Title 18, United States 

Code, Section 1951(b) (2), by attempting to obtain and obtaining 

money and property from and with the consent of "Client-1," a 

client of the enterprise's illegal gambling business, whose 

consent was induced by the wrongful use of actual and threatened 

force, violence, and fear, and thereby attempted to and did 

obstruct, delay, and affect commerce, as that term is defined in 

- 15 -



Title 18, United States Code, Section 1951(b) (3), in violation 

of Title 18, United States Code, Sections 1951 and 2. 

b. In or about May 2012, in the Southern 

District of New York and elsewhere, ALIMZHAN TOKHTAKHOUNOV, 

a/k/a "Taiwanchik," a/k/a "Alik," the defendant, and others 

known and unknown, willfully and knowingly did participate in 

the use of extortionate means, as that term is defined in Title 

18, United States Code, Section 891(7), to collect and attempt 

to collect extensions of credit, as that term is defined in 

Title 18, United States Code, Section 891(1), and to punish a 

person, to wit, Client-1, for the nonrepayment thereof, in 

violation of Title 18, United States Code, Section 894. 

Racketeering Act Four: Extortion of Client-2 

21. VADIM TRINCHER, a/k/a "Dima," the defendant, 

committed the following acts, any one of which alone constitutes 

the commission of Racketeering Act Four: 

a. In or about February 2012, in the Southern 

District of New York and elsewhere, VADIM TRINCHER, a/k/a 

"Dima," the defendant, and others known and unknown, willfully 

and knowingly did commit and attempt to commit extortion, and 

aid and abet the commission of extortion, as that term is 

defined in Title 18, United States Code, Section 1951(b) (2), by 

attempting to obtain and obtaining money and property from and 

with the consent of "Client-2," a client of the enterprise's 

- 16 -



illegal gambling business, whose consent was induced by the 

wrongful use of actual and threatened force, violence, and fear, 

and thereby attempted to and did obstruct, delay, and affect 

commerce, as that term is defined in Title 18, United States 

Code, Section 1951 (b) (3), in violation of Title 18, United 

States Code, Sections 1951 and 2. 

b. In or about February 2012, in the Southern 

District of New York and elsewhere, VADIM TRINCHER, a/k/a 

"Dima," the defendant, and others known and unknown, willfully 

and knowingly did participate in the use of extortionate means, 

as that term is defined in Title 18, United States Code, Section 

891(7), to collect and attempt to collect extensions of credit, 

as that term is defined in Title 18, United States Code, Section 

891(1), and to punish a person, to wit, Client-2, for the 

nonrepayment thereof, in violation of Title 18, United States 

Code, Section 894. 

Racketeering Act Five: Money Laundering Conspiracy 

22. ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 

"Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, 

a/k/a "Tony," the defendants, participated in a sophisticated 

international scheme to launder tens of millions of dollars in 

proceeds from their illegal gambling business through bank 

accounts and shell companies in Cyprus, including from the 

Russia Federation to Cyprus and then back to the Russian 

- 17 -



Federation/ and from the Russian Federation to Cyprus and then 

to the United States. 

a. From at least in or about 2006 1 up to and 

including on or about the date of this Indictment/ in the 

Southern District of New York and elsewhere/ ALIMZHAN 

TOKHTAKHOUN"OV 1 a/k/a "Taiwanchik 1
11 a/k/a "Alik 1

11 VADIM TRINCHERr 

a/k/a "Dimar rr and ANATOLY GOLUBCHIK 1 a/k/a "Tony 1
11 the 

defendants/ and others known and unknown/ willfully and 

knowingly combined/ conspired/ confederated/ and agreed together 

and with each other to violate Sections 1956 (a) (1) (B) (i), 

(a) (2) (A) r and (a) (2) (B) (i) r and 1957 of Title 18 1 United States 

Code. 

b. It was a part and an object of the 

conspiracy that ALIMZHAN TOKHTAKHOUNOV 1 a/k/a "Taiwanchik 1
11 

a/k/a "Alik 1 rr VADIM TRINCHER 1 a/k/a "Dimar rr and ANATOLY 

GOLUBCHIK 1 a/k/ a "Tony r rr the defendants r and others known and 

unknown/ knowing that the property involved in financial 

transactions represented the proceeds of some form of unlawful 

activity/ willfully and knowingly would and did conduct and 

attempt to conduct financial transactions which in fact involved 

the proceeds of specified unlawful activity/ to wit/ an illegal 

gambling business in violation of Title 18 1 United States Coder 

Sections 1955 and 1084 1 and New York Penal Law Section 225.10 1 

knowing that such financial transactions were designed in whole 

- 18 -



and in part to conceal and disguise the nature, location, 

source, ownership and control of the proceeds of such specified 

unlawful activity, in violation of Title 18, United States Code, 

Section 1956 (a) (1) (B) (i) 

c. It was further a part and an object of the 

conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 

a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY 

GOLUBCHIK, a/k/a "Tony," the defendants, and others known and 

unknown, willfully and knowingly would and did transport, 

transmit, and transfer, and attempt to transport, transmit, and 

transfer a monetary instrument and funds from a place in the 

United States to and through a place outside the United States 

and to a place in the United States from and through a place 

outside the United States with the intent to promote the 

carrying on of a specified unlawful activity, to wit, an illegal 

gambling business in violation of Title 18, United States Code, 

Sections 1955 and 1084, and New York Penal Law 225.10, all in 

violation of Title 18, United States Code, Section 

1956 (a) (2) (A). 

d. It was further a part and an object of the 

conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 

a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY 

GOLUBCHIK, a/k/a "Tony," the defendants, and others known and 

unknown, willfully and knowingly would and did transport, 

- 19 -



transmit, and transfer, and attempt to transport, transmit, and 

transfer monetary instruments and funds from a place in the 

United States to and through a place outside the United States 

and to a place in the United States from and through a place 

outside the United States knowing that the monetary instruments 

and funds involved in the transportations, transmissions, and 

transfers represented the proceeds of some form of unlawful 

activity and knowing that such transportations, transmissions, 

and transfers were designed in whole and in part to conceal and 

disguise the nature, the location, the source, the ownership, 

and the control of the proceeds of a specified unlawful 

activity, to wit, an illegal gambling business in violation of 

Title 18, United States Code, Sections 1955 and 1084, and New 

York Penal Law Section 225.10, all in violation of Title 18, 

United States Code, Section 1956(a) (2) (B) (i). 

e. It was further a part and an object of the 

conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 

a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY 

GOLUBCHIK, a/k/a "Tony," the defendants, and others known and 

unknown, in an offense involving and affecting interstate and 

foreign commerce, would and did knowingly engage in and attempt 

to engage in monetary transactions, as that term is defined in 

Title 18, United States Code, Section 1957(f) (1), in criminally 

derived property that was of a value greater than $10,000, to 

- 20 -wit, wire transfers in excess of $10,000 between bank accounts 

in Cyprus controlled by the defendants and bank accounts in the 

United States controlled by the defendants, such property having 

been derived from a specified unlawful activity, to wit, an 

illegal gambling business in violation of Title 18, United 

States Code, Sections 1955 and 1084, and New York Penal Law 

Section 225.10, all in violation of Title 18, United States 

Code, Section 1957. 

Racketeering Act Six: Interstate and Foreign Travel or 
Transportation in Aid of Racketeering Enterprise 

23. In or about January 2010, in the Southern 

District of New York and elsewhere, VADIM TRINCHER, a/k/a 

"Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, 

knowingly and willfully travelled in interstate and foreign 

commerce and used the mail and a facility in interstate and 

foreign commerce with intent to distribute the proceeds of an 

unlawful activity, that is a business enterprise involving 

gambling in violation of Title 18 United States Code Sections 

1955 and 1084, and New York Penal Law Section 225.10, and did 

distribute the proceeds of that unlawful activity, to wit, 

TRINCHER and GOLUBCHIK caused $3,000,000 in proceeds from their 

illegal gambling business to be sent from a bank account they 

controlled in Cyprus to a bank account they controlled in the 

- 21 -



United States, in violation of Title 18, United States Code, 

Section 1952 (a) (1). 

Racketeering Act Seven: Interstate and Foreign Travel and 
Transportation in Aid of Racketeering Enterprise 

24. In or about September 2012, in the Southern 

District of New York and elsewhere, VADIM TRINCHER, a/k/a 

"Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, 

knowingly and willfully travelled in interstate and foreign 

commerce and used the mail and a facility in interstate and 

foreign commerce with intent to distribute the proceeds of an 

unlawful activity, that is a business enterprise involving 

gambling in violation of Title 18 United States Code Sections 

1955 and 1084, and New York Penal Law Section 225.10, and did 

distribute the proceeds of that unlawful activity, to wit, 

TRINCHER and GOLUBCHIK caused approximately $2,200,000 in 

proceeds from their illegal gambling business to be sent from a 

bank account they controlled in Cyprus to a bank account they 

controlled in the United States, in violation of Title 18, 

United States Code, Section 1952(a) (1). 

(Title 18, United States Code, Section 1962(c) .) 

- 22 -



COUNT THREE 

(Racketeering Conspiracy: Nahrnad-Trincher Organization) 

The Grand Jury further charges: 

The Enterprise 

25. At all times relevant to this Indictment, ILLYA 

TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 

Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD 

MCCALMONT, the defendants, and others known and unknown, were 

members and associates of the "Nahmad-Trincher Organization." 

The Nahmad-Trincher Organization was a criminal organization 

whose members and associates engaged in crimes, including 

conducting an illegal gambling business, money laundering, and 

extortion. 

26. The Nahmad-Trincher Organization, including its 

leadership, membership, and associates, constituted an 

"enterprise," as that term is defined in Title 18, United States 

Code, Section 1961(4) -- that is, a group of individuals 

associated in fact. This enterprise was engaged in, and its 

activities affected, interstate and foreign commerce. The 

Nahmad-Trincher Organization was an organized crime group with 

leadership based in New York City and Los Angeles, and that 

operated throughout the United States, including in the Southern 

District of New York, and internationally. The Nahmad-Trincher 

Organization constituted an ongoing organization whose members 

- 23 -



functioned as a continuing unit for a common purpose of 

achieving the objectives of the enterprise. 

27. The criminal conduct of the Nahmad-Trincher 

Organization was directed principally, though not exclusively, 

by its leaders: ILLYA TRINCHER, son of VADIM TRINCHER, a/k/a 

"Dima," HILLEL NAHMAD, a/k/a "Helly," and NOAH SIEGEL, a/k/a 

"The Oracle," the defendants, who were based in New York City. 

ILLYA TRINCHER, NAHMAD, and SIEGEL worked together to lead 

multiple related criminal ventures including an illegal gambling 

business, money laundering, and other crimes. TRINCHER, NAHMAD, 

and SIEGEL were assisted by numerous criminal partners and 

associates throughout the United States, Europe, and elsewhere. 

28. The Nahmad-Trincher Organization was a high­

stakes illegal gambling business run out of New York City and 

Los Angeles that catered primarily to multi-millionaire and 

billionaire clients. The Nahmad-Trincher Organization used 

online gambling websites, operating illegally in the United 

States, to operate an illegal gambling business that generated 

tens of millions of dollars in bets each year. 

29. The Nahmad-Trincher Organization laundered the 

proceeds of the gambling operation through a host of American 

bank accounts and Titan P & H LLC ("Titan"), a plumbing company 

in the Bronx that the Nahmad-Trincher Organization acquired a 

fifty percent interest in as repayment of a gambling debt. 

- 24 -



30. The Nahmad-Trincher Organization was financed by 

a number of different individuals and entities, including the 

Helly Nahmad Gallery in New York City, an art gallery operated 

by HILLEL NAHMAD, a/k/a "Helly," the defendant, in the Carlyle 

Hotel in New York City; NAHMAD's father, a billionaire art 

dealer located in Europe; and JH Capital Inc., an investment 

firm run by JOHN HANSON, the defendant. 

The Defendants 

31. ILLYA TRINCHER, the defendant, was a participant 

in the enterprise, the Nahmad-Trincher Organization, and was a 

leader of the enterprise. In that capacity, TRINCHER 

participated in and profited from various crimes, which he 

committed along with other members and associates of the Nahmad­

Trincher Organization. Among other things, TRINCHER oversaw a 

high-stakes illegal gambling business. 

32. HILLEL NAHMAD, a/k/a "Helly," the defendant, was 

a participant in the enterprise, the Nahmad-Trincher 

Organization, and was a leader of the enterprise. In that 

capacity, NAHMAD participated in and profited from various 

crimes, which he committed along with other members and 

associates of the Nahmad-Trincher Organization. Among other 

things, NAMHAD worked with TRINCHER to launder tens of millions 

of dollars on behalf of the illegal gambling business. 

- 25 -



33. NOAH SIEGEL, a/k/a "The Oracle," the defendant, 

was a participant in the enterprise, the Nahmad-Trincher 

Organization, and was a leader of the enterprise. In that 

capacity, SIEGEL participated in and profited from various 

crimes, which he committed along with other members and 

associates of the Nahmad-Trincher Organization. Among other 

things, SIEGEL worked with TRINCHER to oversee a high-stakes 

illegal gambling business. 

34. JOHN HANSON, ARTHUR AZEN, JOHN HIRSCH, and DON 

MCCALMONT, the defendants, were also participants in the 

enterprise, the Nahmad-Trincher Organization. In this capacity, 

these defendants participated in and profited from various 

crimes, including operating an illegal gambling business and 

money laundering, which they committed along with other members 

and associates of the Nahmad-Trincher Organization. 

Purposes of the Enterprise 

35. The purposes of the enterprise included the 

following: 

a. enriching the leaders, members, and 

associates of the enterprise through an illegal gambling 

business, money laundering, extortion, and other crimes; and 

b. avoiding detection of their illegal conduct 

in order to continue to enrich themselves. 

- 26 -



Means and Methods of the Enterprise 

36. Among the means and methods by which ILLYA 

TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 

Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD 

MCCALMONT, the defendants, and their co-conspirators, and other 

members and associates conducted and participated in the conduct 

of the affairs of the Nahmad-Trincher Organization were the 

following: 

a. Members and associates of the Nahmad­

Trincher Organization and their co-conspirators worked together 

on a range of criminal money-making schemes, including operating 

an illegal international gambling business that catered to 

multi-millionaires and billionaires. 

b. Members and associates of the Nahmad­

Trincher Organization and their co-conspirators employed a 

sophisticated money laundering scheme to launder tens of 

millions of dollars through various bank accounts and 

corporations, including Titan. 

The Racketeering Conspiracy 

37. From at least in or about 2006, up to and 

including on or about the date of this Indictment, ILLYA 

TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 

Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD 

MCCALMONT, the defendants, and others known and unknown, in the 

- 27 -



Southern District of New York and elsewhere, being persons 

employed by and associated with the racketeering enterprise 

described in paragraphs 25 through 34 above, namely, the Nahmad­

Trincher Organization, which enterprise was engaged in, and the 

activities of which affected, interstate and foreign commerce, 

willfully and knowingly combined, conspired, confederated, and 

agreed together and with each other to violate Title 18, United 

States Code, Section 1962(c), to wit, to conduct and 

participate, directly and indirectly, in the conduct of such 

enterprise's affairs through the collection of unlawful debt as 

set forth in paragraph 38 below, and through a pattern of 

racketeering activity as set forth below in paragraph 39. 

Collection of Unlawful Debt 

38. The collection of unlawful debt, as that term is 

defined in Title 18, United States Coder Section 1961(6) r 

through which the defendants and their co-conspirators agreed to 

conduct and participate directly and indirectly in the conduct 

of the affairs of the enterpriser consisted of the collection of 

unlawful gambling debts/ that isr debts incurred and contracted 

in gambling activity which was in violation of the law of the 

United States and the law of the State of New York and which was 

incurred in connection with a business of gambling in violation 

of the law of the United States and the law of the State of New 

York. It was a part of the conspiracy that each defendant 

- 28 -



agreed that a conspirator would commit at least one collection 

of unlawful debt in the conduct of the affairs of the 

enterprise. 

The Pattern of Racketeering 

39. The pattern of racketeering activity, as defined 

in Title 18, United States Code, Sections 1961(1) and 1961(5), 

through which ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH 

SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR 

AZEN, and DONALD MCCALMONT, the defendants, and .their co­

conspirators agreed to conduct and participate in the conduct of 

the affairs of the enterprise consisted of multiple acts 

indictable under the following federal and state statutes: 

a. Title 18, United States Code, Section 1955 

(operation of an illegal gambling business); 

b. Title 18, United States Code, Sections 1956 

and 1957 (money laundering); 

c. Title 18, United States Code, Section 1084 

(transmission of wagering information) ; 

d. Title 18, United States Code, Section 1952 

(interstate and foreign travel and transportation in aid of 

racketeering enterprises); 

e. Title 18, United States Code, Section 894 

(collection of extensions of credit by extortionate means); and 

- 29 -



f. multiple acts involving gambling, in 

violation of New York Penal Law Section 225.10. 

It was further a part of the conspiracy that the defendants 

agreed that a conspirator would commit at least two acts of 

racketeering activity in the conduct of the affairs of the 

enterprise. 

(Title 18, United States Code, Section 1962(d) .) 

COUNT FOUR 

(Racketeering: Nahmad-Trincher Organization) 

The Grand Jury further charges: 

40. The allegations contained in paragraphs 25 

through 39 above are hereby repeated, realleged, and 

incorporated by reference herein as though fully set forth at 

length for the purpose of alleging Count Four of this 

Indictment. 

41. From at least in or about 2006, up to and 

including on or about the date of this Indictment ILLYA 

TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 

Oracle," ARTHUR AZEN, DON MCCALMONT and JOHN HANSON, the 

defendants, and others known and unknown, in the Southern 

District of New York and elsewhere, being persons employed by 

and associated with the racketeering enterprise described in 

paragraphs 25 through 39 above, namely, the Nahmad-Trincher 

- 30 -



Organization, which enterprise was engaged in, and the 

activities of which affected, interstate and foreign commerce, 

willfully and knowingly did conduct and participate, directly 

and indirectly, in the conduct of such enterprise's affairs 

through a pattern of racketeering activity, as described in 

paragraphs 42 through 49, and the collection of unlawful debt, 

as described in paragraph 50. 

The Pattern of Racketeering 

42. The pattern of racketeering activity, as defined 

in Title 18, United States Code, Sections 1961(1) and 1961(5), 

consisted of the following acts: 

Racketeering Act One: Illegal Gambling Business 

43. ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 

NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the 

defendants, operated an illegal international gambling business 

that catered primarily to celebrities, professional poker 

players, and very wealthy individuals working in the financial 

industry. The defendants committed the following acts, any of 

which alone constitutes the commission of Racketeering Act One: 

a. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ILLYA TRINCHER, 

HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," 

and JOHN HANSON, the defendants, knowingly and willfully did 

- 31 -



conduct, finance, manage, supervise, direct, and own all and 

part of an illegal gambling business, as that term is defined in 

Title 18, United States Code, Section 1955 (b) (1), (2), and (3), 

to wit, the defendants operated a bookmaking business which 

violated New York Penal Law 225.10, involved five or more 

persons who conducted, financed, managed, supervised, directed, 

and owned all or part of such business, and had been and 

remained in substantially continuous operation for a period in 

excess of thirty days and had a gross revenue of $2,000 in any 

single day, in violation of Title 18 United States Code, Section 

1955 (a) . 

b. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ILLYA TRINCHER, 

HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," 

and JOHN HANSON, the defendants, knowingly and willfully did 

advance and profit from unlawful gambling activity by engaging 

in bookmaking to the extent that they received and accepted in 

any one day more than five bets totaling more than $5,000, in 

violation of New York Penal Law Section 225.10. 

c. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ILLYA TRINCHER, 

HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," 

- 32 -



and JOHN HANSON, the defendants, knowingly and willfully being 

engaged in the business of betting and wagering, did use a wire 

communication facility for the transmission in interstate and 

foreign commerce of bets and wagers and information assisting in 

the placing of bets and wagers on sporting events and contests, 

and for the transmission of wire communications which entitled 

the recipient to receive money and credit as a result of bets 

and wagers, and for information assisting in the placing of bets 

and wagers, in violation of Title 18, United States Code, 

Section 1084. 

Racketeering Act Two: Extortion of Client-3 

44. From at least in or about 2010, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ILLYA TRINCHER, DON 

MCCALMONT, ARTHUR AZEN, and JOHN HANSON, the defendants, and 

others known and unknown, willfully and knowingly did 

participate in the use of extortionate means, as that term is 

defined in Title 18, United States Code, Section 891(7), to 

collect and attempt to collect extensions of credit, as that 

term is defined in Title 18, United States Code, Section 891(1), 

and to punish a person, to wit, "Client-3," for the nonrepayment 

thereof, in violation of Title 18, United States Code, Section 

894 (a) (1) and (2). 

- 33 -



Racketeering Act Three: Money Laundering Conspiracy 

45. ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 

NOAH SIEGEL, a/k/a "The Oracle," DON MCCALMONT, ARTHUR AZEN, and 

JOHN HANSON, the defendants, participated in an international 

conspiracy to launder tens of millions of dollars in proceeds 

from their illegal gambling business. From at least in or about 

2006, up to and including on or about the date of this 

Indictment, in the Southern District of New York and elsewhere, 

ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a 

"The Oracle," and JOHN HANSON, the defendants, and others known 

and unknown, willfully and knowingly combined, conspired, 

confederated, and agreed together and with each other to violate 

Sections 1956 (a) (1) (A) (i), (a) (1) (A) (ii), (a) (1) (B) (i), 

(a) (2) (A), and (a) (2) (B) (i), and 1957 of Title 18, United States 

Code. 

a. It was a part and an object of the conspiracy 

that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, 

a/k/a "The Oracle," and JOHN HANSON, the defendants, and others 

known and unknown, knowing that the property involved in 

financial transactions represented the proceeds of some form of 

unlawful activity, willfully and knowingly would and did conduct 

and attempt to conduct financial transactions which in fact 

involved the proceeds of specified unlawful activity, to wit, an 

illegal gambling business in violation of Title 18, United 

- 34 -



States Code, Sections 1955 and 1084, and New York Penal Law 

Section 225.10, knowing that such financial transactions were 

conducted with the intent to promote the carrying on of 

specified unlawful activity, to wit, an illegal gambling 

business, in violation of Title 18, United States Code, Section 

1956 (a) (1) (A) (i). 

b. It was further a part and an object of the 

conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 

NOAH SIEGEL, a/k/a "The Oracle," ARTHUR AZEN, DON MCCALMONT, and 

JOHN HANSON, the defendants, and others known and unknown, 

knowing that the property involved in financial transactions 

represented the proceeds of some form of unlawful activity, 

willfully and knowingly would and did conduct and attempt to 

conduct financial transactions which in fact involved the 

proceeds of specified unlawful activity, to wit, an illegal 

gambling business in violation of Title 18, United States Code, 

Sections 1955 and 1084, and New York Penal Law Section 225.10, 

knowing that such financial transactions were conducted with the 

intent to engage in conduct constituting a violation of sections 

7201 and 7206 of the Internal Revenue Code of 1986, in violation 

of Title 18, United States Code, Section 1956(a) (1) (A) (ii). 

c. It was further a part and an object of the 

conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 

NOAH SIEGEL, a/k/a "The Oracle," ARTHUR AZEN, DON MCCALMONT, and 

- 35 -



JOHN HANSON, the defendants, and others known and unknown, 

knowing that the property involved in financial transactions 

represented the proceeds of some form of unlawful activity 

willfully and knowingly would and did conduct and attempt to 

conduct financial transactions which in fact involved the 

proceeds of specified unlawful activity, to wit, an illegal 

gambling business in violation of Title 18, United States Code, 

Sections 1955 and 1084, and New York Penal Law Section 225.10, 

knowing that such financial transactions were designed in whole 

and in part to conceal and disguise the nature, location, 

source, ownership and control of the proceeds of specified 

unlawful activity, in violation of Title 18, United States Code, 

Section 1956(a) (1) (B) (i) 

d. It was further a part and an object of the 

conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 

NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the 

defendants, and others known and unknown, willfully and 

knowingly would and did transport, transmit, and transfer, and 

attempt to transport, transmit, and transfer a monetary 

instrument and funds from a place in the United States to and 

through a place outside the United States and to a place in the 

United States from and through a place outside the United States 

with the intent to promote the carrying on of a specified 

unlawful activity, to wit, an illegal gambling business in 

- 36 -



violation of Title 18, United States Code, Sections 1955 and 

1084, and New York Penal Law Section 225.10, all in violation of 

Title 18, United States Code, Section 1956(a) (2) (A). 

e. It was further a part and an object of the 

conspiracy that ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 

NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the 

defendants, and others known and unknown, in an offense 

involving and affecting interstate and foreign commerce, would 

and did engage in and attempt to engage in monetary 

transactions, as that term is defined in Title 18, United States 

Code, Section 1957(f) (1), in criminally derived property that 

was of a value greater than $10,000, to wit, wire transfers in 

excess of $10,000 between various bank accounts controlled by 

the defendants and clients of the illegal gambling business, 

such property having been derived from a specified unlawful 

activity, to wit, an illegal gambling business in violation of 

Title 18, United States Code, Sections 1955 and 1084, and New 

York Penal Law Section 225.10, all in violation of Title 18, 

United States Code, Section 1957. 

Racketeering Act Four: Interstate and Foreign Travel and 
Transportation in Aid of Racketeering Enterprise 

46. On or about September 12, 2012, in the Southern 

District of New York and elsewhere, HILLEL NAHMAD, a/k/a "Helly 

Nahmad," the defendant, knowingly and willfully travelled in 

- 37 -



interstate and foreign commerce and used the mail and a facility 

in interstate and foreign commerce with intent to otherwise 

promote, manage, establish, carry on, and facilitate the 

promotion, management, establishment, and carrying on, of an 

unlawful activity, that is a business enterprise involving 

gambling in violation of Title 18 United States Code Sections 

1955 and 1084, and New York Penal Law Section 225.10, and did 

promote, manage, establish, carry on, and facilitate the 

promotion, management, establishment, and carrying on of an 

unlawful activity, to wit, NAHMAD caused $500,000 to be sent 

from his father's bank account in Switzerland to ILLYA TRINCHER, 

the defendant, in the United States, in violation of Title 18, 

United States Code, Section 1952(a) (1). 

Racketeering Act Five: Interstate and Foreign Travel and 
Transportation in Aid of Racketeering Enterprise 

47. On or about September 12, 2012, in the Southern 

District of New York and elsewhere, ILLYA TRINCHER, the 

defendant, knowingly and willfully travelled in interstate and 

foreign commerce and used the mail and a facility in interstate 

and foreign commerce with intent to otherwise promote, manage, 

establish, carry on, and facilitate the promotion, management, 

establishment, and carrying on, of an unlawful activity, that is 

a business enterprise involving gambling in violation of Title 

18 United States Code Sections 1955 and 1084, and New York Penal 

- 38 -



Law Section 225.10 1 and did promoter manager establish/ carry 

on 1 and facilitate the promotion/ management/ establishment/ and 

carrying on of an unlawful activity/ to witr TRINCHER caused 

four hundred/ $99 1 800 to be sent from his bank account in New 

York to an account in Taiwan that was controlled by an online 

gambling website operating illegally in the United States 1 in 

violation of Title 18 1 United States Code 1 Section 1952(a) (1) 

Racketeering Act Six: Interstate and Foreign Travel and 
Transportation in Aid of Racketeering Enterprise 

48. On or about June 4 1 2011 1 in the Southern 

District of New York and elsewhere/ HILLEL NAHMAD 1 a/k/a "Helly 

Nahmad 1
11 the defendant 1 knowingly and willfully travelled in 

interstate and foreign commerce and used the mail and a facility 

in interstate and foreign commerce with intent to otherwise 

promoter manager establish/ carry onr and facilitate the 

promotion/ management/ establishment/ and carrying onr of an 

unlawful activity/ that is a business enterprise involving 

gambling in violation of Title 18 United States Code Sections 

1955 and 1084 1 and New York Penal Law Section 225.10 1 and did 

promoter manager establish/ carry onr and facilitate the 

promotion/ management/ establishment/ and carrying on of an 

unlawful activity/ to witr NAHMAD caused $850 1 000 to be sent 

from his father 1 S bank account in Switzerland to a bank account 

under the control of NOAH SIEGEL 1 a/k/a "the Oracle 1
11 in the 

- 39 -



United States, in violation of Title 18, United States Code, 

Section 1952 (a) (1) 

Racketeering Act Seven: 
Transmission of Wagering Information 

49. ILLYA TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 

NOAH SIEGEL, a/k/a "The Oracle," and JOHN HANSON, the 

defendants, were in the business of illegally betting on 

professional sporting events and placed millions of dollars of 

bets through online gambling websites operating illegally in the 

United States. From at least in or about 2008, up to and 

including on or about the date of this indictment, in the 

Southern District of New York and elsewhere, ILLYA TRINCHER, 

HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The Oracle," 

and JOHN HANSON, the defendants, knowingly and willfully being 

engaged in the business of betting and wagering, did use a wire 

communication facility for the transmission in interstate and 

foreign commerce of bets and wagers and information assisting in 

the placing of bets and wagers on sporting events and contests, 

and for the transmission of wire communications which entitled 

the recipient to receive money and credit as a result of bets 

and wagers, and for information assisting in the placing of bets 

and wagers, in violation of Title 18, United States Code, 

Section 1084. 

- 40 -Collection of Unlawful Debt 

50. The collection of unlawful debt defined by Title 

18, United States Code, Section 1961(6), that is, a debt (A) 

incurred and contracted in gambling activity which was in 

violation of a law of the United States of America and a law of 

the State of New York, and (B) which was incurred in connection 

with the business of gambling in violation of a law of the 

United States of America, New York State, and a political 

subdivision thereof, through which ILLYA TRINCHER, HILLEL 

NAHMAD, a/k/a "Belly," NOAH SIEGEL, a/k/a "The Oracle," JOHN 

HANSON, ARTHUR AZEN, and DONALD MCCALMONT, the defendants, did 

conduct and participate in the affairs of the enterprise, which 

was engaged in and the activities of which affected interstate 

commerce, consisted of collecting and attempting to collect an 

unlawful debt as follows: 

a. From at least in or about 2010, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ILLYA TRINCHER, 

HILLEL NAHMAD, a/k/a "Belly," NOAH SIEGEL, a/k/a "The Oracle," 

ARTHUR AZEN, DON MCCALMONT, and JOHN HANSON, the defendants, 

participated in the collection and attempted collection of more 

than $2,000,000 of unlawful gambling debts from Client-3 by, 

among other things, acquiring a fifty percent interest in 

Client-3's plumbing company, Titan. 

- 41 -



(Title 18, United States Code, Section 1962(c) .) 

COUNT FIVE 

(Illegal Sports Gambling Business: 
Taiwanchik-Trincher Organization) 

The Grand Jury further charges: 

51. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," the 

defendants, knowingly and willfully did conduct, finance, 

manage, supervise, direct, and own all and part of an illegal 

gambling business, as that term is defined in Title 18, United 

States Code, Section 1955 (b) (1), (2), and (3), to wit, the 

defendants operated a bookmaking business that violated New York 

Penal Law Section 225.10, involved five or more persons who 

conducted, financed, managed, supervised, directed, and owned 

all or part of such business, and had been and remained in 

substantially continuous operation for a period in excess of 

thirty days and had a gross revenue of $2,000 in any single day. 

(Title 18, United States Code, Sections 1955 and 2.) 

- 42 -



COUNT SIX 

(Acceptance of Financial Instrument for Unlawful Internet 
Gambling: Taiwanchik-Trincher Organization) 

The Grand Jury further charges: 

52. From at least in or about 2007, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM TRINCHER, a/k/a 

"Dima," and ANATOLY GOLUBCHIK, the defendants, who were engaged 

in the business of betting and wagering, knowingly and willfully 

did accept, in connection with the participation of another 

person in unlawful Internet gambling, credit, and the proceeds 

of credit, extended to and on behalf of such other person 

(including credit extended through the use of a credit card); an 

electronic fund transfer, and funds transmitted by and through a 

money transmitting business, and the proceeds of an electronic 

fund transfer and money transmitting service, from and on behalf 

of such other person; a check, draft, and similar instrument 

which was drawn by and on behalf of such other person and was 

drawn on and payable at and through a financial institution; and 

the proceeds of another form of financial transaction, as the 

Secretary and the Board of Governors of the Federal Reserve 

System may jointly prescribe by regulation, which involves a 

financial institution as a payor and financial intermediary on 

- 43 -



behalf of and for the benefit of such other person, to wit, 

TOKHTAKHOUNOV, TRINCHER, and GOLUBCHIK operated an illegal 

bookmaking business that utilized gambling websites operating 

illegally in the United States. 

(Title 31, United States Code, Sections 5363 and 5366; 
Title 18, United States Code, Section 2.) 

COUNT SEVEN 

(Money Laundering Conspiracy: Taiwanchik-Trincher Organization) 

The Grand Jury further charges: 

53. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and 

SLAVA GREENBERG, a/k/a "Stan," the defendants, and others known 

and unknown, willfully and knowingly combined, conspired, 

confederated, and agreed together and with each other to violate 

Title 18, United States Code, Sections 1956 (a) (1) (B) (i), 

(a) (2) (A), and (a) (2) (B) (i), and 1957, to wit, the defendants 

laundered more than $50,000,000 in sports gambling proceeds 

through shell companies in Cyprus and the United States of 

America. 

54. It was a part and an object of the conspiracy 

that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," 

- 44 -



VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," 

MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," the defendants, 

and others known and unknown, knowing that the property involved 

in financial transactions represented the proceeds of some form 

of unlawful activity willfully and knowingly would and did 

conduct and attempt to conduct financial transactions which in 

fact involved the proceeds of specified unlawful activity, to 

wit, an illegal gambling business in violation of Title 18, 

United States Code, Sections 1955 and 1084, and New York Penal 

Law Section 225.10, knowing that such financial transactions 

were designed in whole and in part to conceal and disguise the 

nature, location, source, ownership and control of the proceeds 

of specified unlawful activity, in violation of Title 18, United 

States Code, Section 1956(a) (1) (B) (i). 

55. It was further a part and an object of the 

conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 

a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, 

a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," 

the defendants, and others known and unknown, willfully and 

knowingly would and did transport, transmit, and transfer, and 

attempt to transport, transmit, and transfer a monetary 

instrument and funds from a place in the United States to and 

through a place outside the United States and to a place in the 

United States from and through a place outside the United States 

- 45 -



with the intent to promote the carrying on of a specified 

unlawful activity, to wit, an illegal gambling business in 

violation of Title 18, United States Code, Sections 1955 and 

1084, and New York Penal Law Section 225.10, all in violation of 

Title 18, United States Code, Section 1956 (a) (2) (A). 

56. It was further a part and an object of the 

conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 

a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, 

a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," 

the defendants, and others known and unknown, willfully and 

knowingly would and did transport, transmit, and transfer, and 

attempt to transport, transmit, and transfer monetary 

instruments and funds from a place in the United States to and 

through a place outside the United States and to a place in the 

United States from and through a place outside the United States 

knowing that the monetary instruments and funds involved in the 

transportations, transmissions, and transfers represented the 

proceeds of some form of unlawful activity and knowing that such 

transportations, transmissions, and transfers were designed in 

whole and in part to conceal and disguise the nature, the 

location, the source, the ownership, and the control of the 

proceeds of a specified unlawful activity, to wit, an illegal 

gambling business in violation of Title 18, United States Code, 

Sections 1955 and 1084, and New York Penal Law Section 225.10, 

- 46 -



all in violation of Title 18, United States Code, Section 

1956 (a) (2) (B) (i). 

57. It was further a part and an object of the 

conspiracy that ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 

a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, 

a/k/a "Tony," MICHAEL SALL, and SLAVA GREENBERG, a/k/a "Stan," 

the defendants, and others known and unknown, in an offense 

involving and affecting interstate and foreign commerce, would 

and did engage in and attempt to engage in monetary 

transactions, as that term is defined in Title 18, United States 

Code, Section 1957(f) (1), in criminally derived property that 

was of a value greater than $10,000, to wit, wire transfers in 

excess of $10,000 between bank accounts in Cyprus controlled by 

the defendants and bank accounts in the United States controlled 

by the defendants, such property having been derived from a 

specified unlawful activity, to wit, an illegal gambling 

business in violation of Title 18, United States Code, Sections 

1955 and 1084, and New York Penal Law Section 225.10, all in 

violation of Title 18, United States Code, Section 1957. 

(Title 18, United States Code, Section 1956(h) .) 

COUNT EIGHT 

(To Collect Extensions of Credit by Extortionate Means) 

The Grand Jury further charges: 

- 47 -



58. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," the defendants, 

and others known and unknown, knowingly and willfully combined, 

conspired, confederated, and agreed together and with each other 

to participate in the use of extortionate means, as that term is 

defined in Title 18, United States Code, Section 891(7), to 

collect and attempt to collect extensions of credit, as that 

term is defined in Title 18, United States Code, Section 891(1), 

and to punish a person, to wit, gamblers who owed sports 

gambling debts, for the nonrepayrnent thereof, to wit, 

TOKHTAKHOUNOV, TRINCHER, and GOLUBCHIK, agreed to use violence 

and threats of violence to collect sports gambling debts from 

gamblers. 

(Title 18, United States Code, Section 894.) 

COUNT NINE 

(Illegal Sports Gambling Business: 
Nahmad-Trincher Organization) 

The Grand Jury further charges: 

59. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, HILLEL NAHMAD, 

- 48 -



a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," 

JOHN HANSON, JONATHAN HIRSCH, JUSTIN SMITH, WILLIAM EDLER, PETER 

FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a "D.A.," BRYAN ZURIFF, 

and ABRAHAM MOSSERI, the defendants, knowingly and willfully did 

conduct, finance, manage, supervise, direct, and own all and 

part of an illegal gambling business, as that term is defined in 

Title 18, United States Code, Section 1955 (b) (1), (2), and (3), 

and aid and abet the same, to wit, NAHMAD, TRINCHER, SIEGEL, 

HANSON, HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, AARON, ZURIFF, and 

MOSSERI, operated a bookmaking business that violated New York 

Penal Law Section 225.10, involved five or more persons who 

conducted, financed, managed, supervised, directed, and owned 

all or part of such business, and had been and remained in 

substantially continuous operation for a period in excess of 

thirty days and had a gross revenue of $2,000 in any single day. 

(Title 18, United States Code, Sections 1955 and 2.) 

COUNT TEN 

(Transmission of Sports Wagering Information: 
Nahmad-Trincher Organization) 

The Grand Jury further charges: 

60. From at least in or about 2008, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, HILLEL NAHMAD, 

a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," 

- 49 -



JOHN HANSON, and JONATHAN HIRSCH, the defendants, being engaged 

in the business of betting and wagering, knowingly and willfully 

did use a wire communication facility for the transmission in 

interstate and foreign commerce of bets and wagers and 

information assisting in the placing of bets and wagers on a 

sporting event and contest, and for the transmission of a wire 

communication which entitled the recipient to receive money and 

credit as a result of bets and wagers, and for information 

assisting in the placing of bets and wagers, and aided and 

abetted the same, to wit, NAHMAD, TRINCHER, SIEGEL, HANSON, 

HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, AARON, ZURIFF, and 

MOSSERI, the defendants transmitted wagering information 

concerning sporting events via emails sent across state lines. 

(Title 18, United States Code, Sections 1084 and 2.) 

COUNT ELEVEN 

(Acceptance of Financial Instrument for Unlawful Internet 
Sports Gambling: Trincher-Nahmad Organization) 

The Grand Jury further charges: 

61. From at least in or about 2008, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, HILLEL NAHMAD, 

a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," 

JOHN HANSON, JONATHAN HIRSCH, a/k/a "Hersch," JUSTIN SMITH, 

WILLIAM EDLER, PETER FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a 

- 50 -



"D.A. ," BRYAN ZURIFF, and ABRAHAM MOSSERI, the defendants, who 

were engaged in the business of betting and wagering, knowingly 

and willfully did accept, in connection with the participation 

of another person in unlawful Internet gambling, credit, and the 

proceeds of credit, extended to and on behalf of such other 

person (including credit extended through the use of a credit 

card); an electronic fund transfer, and funds transmitted by and 

through a money transmitting business, and the proceeds of an 

electronic fund transfer and money transmitting service, from 

and on behalf of such other person; a check, draft, and similar 

instrument which was drawn by and on behalf of such other person 

and was drawn on and payable at and through a financial 

institution; and the proceeds of another form of financial 

transaction, as the Secretary and the Board of Governors of the 

Federal Reserve System may jointly prescribe by regulation, 

which involved a financial institution as a payor and financial 

intermediary on behalf of and for the benefit of such other 

person, and aided and abetted the same, to wit, NAHMAD, 

TRINCHER, SIEGEL, HANSON, HIRSCH, SMITH, EDLER, FELDMAN, ORATZ, 

AARON, ZURIFF, and MOSSERI, operated an illegal bookmaking 

business that utilized gambling websites operating illegally in 

the United States. 

(Title 31, United States Code, Sections 5363 and 5366; 
Title 18, United States Code, Section 2.) 

- 51 - < 

i 

! 



COUNT TWELVE 

(Money Laundering Conspiracy: Nahmad-Trincher Organization) 

The Grand Jury further charges: 

62. From at least in or about 2006, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, HILLEL NAHMAD, 

a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," 

JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, EDWIN TING, a/k/a 

"Eddie," EUGENE TRINCHER, PETER SKYLLAS, and RONALD UY, the 

defendants, and others known and unknown, knowingly and 

willfully did combine, conspire, confederate, and agree together 

and with each other to violate Title 18, United States Code, 

Sections, 1956(a) (1) (A) (i), (a) (1) (A) (ii), (a) (1) (B) (i), 

(a) (2) (A), and (a) (2) (B) (i), and 1957 of Title 18, United States 

Code .. 

63. It was a part and an object of the conspiracy 

that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, 

a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON MCCALMONT, 

EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER SKYLLAS, and 

RONALD UY, the defendants, and others known and unknown, knowing 

that the property involved in financial transactions represented 

the proceeds of some form of unlawful activity, willfully and 

knowingly would and did conduct and attempt to conduct financial 

- 52 -



transactions which in fact involved the proceeds of specified 

unlawful activity, to wit, an illegal gambling business in 

violation of Title 18, United States Code, Sections 1955 and 

1084, and New York Penal Law Sections 225.10, knowing that such 

financial transactions were conducted with the intent to promote 

the carrying on of specified unlawful activity, to wit, an 

illegal gambling business, to wit the defendants laundered more 

than $50,000,000 in gambling proceeds through various bank 

accounts and businesses, in violation of Title 18, United States 

Code, Section 1956 (a) (1) (A) (i). 

64. It was further a part and an object of the 

conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, 

NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON 

MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER 

SKYLLAS, and RONALD UY, the defendants, and others known and 

unknown, knowing that the property involved in financial 

transactions represented the proceeds of some form of unlawful 

activity, willfully and knowingly would and did conduct and 

attempt to conduct financial transactions which in fact involved 

the proceeds of specified unlawful activity, to wit, an illegal 

gambling business in violation of Title 18, United States Code, 

Sections 1955 and 1084, and New York Penal Law Section 225.10, 

knowing that such financial transactions were conducted with the 

intent to engage in conduct constituting a violation of section 

- 53 -



7201 and 7206 of the Internal Revenue Code of 1986, in violation 

of Title 18, United States Code, Section 1956(a) (1) (A) (ii). 

65. It was further a part and an object of the 

conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, 

NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON 

MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER 

SKYLLAS, and RONALD UY, the defendants, and others known and 

unknown, knowing that the property involved in such financial 

transactions represented the proceeds of some form of unlawful 

activity, willfully and knowingly would and did conduct and 

attempt to conduct financial transactions which in fact involved 

the proceeds of specified unlawful activity, to wit, an illegal 

gambling business in violation of Title 18, United States Code, 

Sections 1955 and 1084, and New York Penal Law Section 225.10, 

knowing that such financial transactions were designed in whole 

and in part to conceal and disguise the nature, location, 

source, ownership and control of the proceeds of specified 

unlawful activity, in violation of Title 18, United States Code, 

Section 1956 (a) (1) (B) (i). 

66. It was further a part and an object of the 

conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, 

NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, and RONALD UY, the 

defendants, and others known and unknown, willfully and 

knowingly would and did transport, transmit, and transfer, and 

- 54 -



attempt to transport, transmit, and transfer a monetary 

instrument and funds from a place in the United States to and 

through a place outside the United States and to a place in the 

United States from and through a place outside the United States 

with the intent to promote the carrying on of a specified 

unlawful activity, to wit, an illegal gambling business in 

violation of Title 18, United States Code, Sections 1955 and 

1084, and New York Penal Law Section 225.10, all in violation of 

Title 18, United States Code, Section 1956 (a) (2) (A). 

67. It was further a part and an object of the 

conspiracy that HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, 

NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, ARTHUR AZEN, DON 

MCCALMONT, EDWIN TING, a/k/a "Eddie," EUGENE TRINCHER, PETER 

SKYLLAS, and RONALD UY, the defendants, and others known and 

unknown, in an offense involving and affecting interstate and 

foreign commerce, would and did engage in and attempt to engage 

in monetary transactions, as that term is defined in Title 18, 

United States Code, Section 1957(f) (1), in criminally derived 

property that was of a value greater than $10,000, to wit, wire 

transfers in excess of $10,000 between various bank accounts 

controlled by the defendants and clients of the illegal gambling 

business, such property having been derived from a specified 

unlawful activity, to wit, an illegal gambling business in 

violation of Title 18, United States Code, Sections 1955 and 

- 55 -



1084 1 and New York Penal Law Section 225.10 1 all in violation of 

Title 18 1 United States Coder Section 1957. 

(Title 18 1 United States Coder Section 1956(h). 

COUNT THIRTEEN 

(Structuring) 

The Grand Jury further charges: 

68. From at least in or about January 2012 1 up to and 

including on or about the date of this Indictment 1 in the 

Southern District of New York and elsewhere/ RONALD UY and ILLYA 

TRINCHER 1 the defendants/ knowingly and willfully/ and for the 

purpose of evading the reporting requirements of Section 5313(a) 

of Title 31 1 United States Coder and the regulations promulgated 

thereunder/ did structure and assist in structuring/ and 

attempted to structure and assist in structuring/ a transaction 

with one and more domestic financial institutions/ and did aid 

and abet the samer to wit 1 RONALD UY 1 a branch manager at a 

JPMorgan Chase Bank located in New York City (the "Bank") r did 

assist TRINCHER in structuring several transactions at the Bank 

designed in part to avoid generating currency transaction 

reports. 

(Title 31 1 United States Coder Sections 5324 (a) (3) and (d) (1) 
Title 18 1 United Stated Coder Section 2.) 

- 56 -



COUNT FOURTEEN 

(Extortion of Client-3) 

The Grand Jury further charges: 

69. From at least in or about January 2010, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ILLYA TRINCHER, 

ARTHUR AZEN, DON MCCALMONT, and JOHN HANSON, the defendants, 

willfully and knowingly did participate in the use of 

extortionate means, as that term is defined 1n Title 18, United 

States Code, Section 891(7), to collect and attempt to collect 

extensions of credit, as that term is defined in Title 18, 

United States Code, Section 891(1), and to punish a person, to 

wit, Client-3, for the nonrepayment thereof, to wit, TRINCHER, 

AZEN, MCCALMONT, and HANSON threatened to cause, and did cause, 

harm to Titan, Client-3's plumbing company, to collect and 

attempt to collect a $2,000,000 gambling debt that Client-3 owed 

to the Trincher-Nahmad Organization. 

(Title 18, United States Code, Sections 894(a) (1) and (a) (2) .) 

COUNT FIFTEEN 

(Wire Fraud Conspiracy) 

The Grand Jury further charges: 

70. From at least in or about March 2012, up to and 

including on or about the date of this indictment, in the 

Southern District of New York and elsewhere, HILLEL NAHMAD, 

- 57 -



a/k/a "Helly," and NICHOLAS HIRSH, the defendants, and others 

known and unknown, knowingly and willfully did combine, 

conspire, confederate, and agree together and with each other to 

violate Title 18, United States Code, Section 1343. 

71. It was a part and an object of the conspiracy 

that HILLEL NAHMAD, a/k/a "Helly," and NICHOLAS HIRSH, the 

defendants, and others known and unknown, having devised and 

intending to devise any 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 and foreign commerce, a 

writing, sign, signal, picture, and sound for the purpose of 

executing such scheme and artifice, in violation of Title 18, 

United States Code, Section 1343, to wit, HILLEL NAHMAD, a/k/a 

"Helly," and NICHOLAS HIRSCH used interstate and international 

wires in furtherance of a scheme to defraud an individual 

concerning a sale of a piece of art that they claimed to be 

worth approximately $300,000 but was in fact worth at least 

approximately $50,000 less. 

(Title 18, United States Code, Section 1349.) 

- 58 -



COUNT SIXTEEN 

(Illegal Sports Gambling Business: Druzhinsky Organization) 

The Grand Jury further charges: 

72. From at least in or about 2008~ up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, DMITRY DRUZHINSKY, 

ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a 

"Murashka," and ARTHUR AZEN, the defendants, knowingly and 

willfully did conduct, finance, manage, supervise, direct, and 

own all and part of an illegal gambling business, as that term 

is defined in Title 18, United States Code, Section 1955 (b) (1), 

(2), and (3), to wit, DRUZHINSKY, ZAVERUKHA, KATCHALOFF, and 

AZEN operated a bookmaking business that violated New York Penal 

Law Section 225.10, involved five or more persons who conducted, 

financed, managed, supervised, directed, and owned all or part 

of such business, and had been and remained in substantially 

continuous operation for a period in excess of thirty days and 

had a gross revenue of $2,000 in any single day. 

(Title 18, United States Code, Sections 1955 and 2.) 

- 59 -



COUNT SEVENTEEN 

(Acceptance of Financial Instrument 
for Unlawful Internet Sports Gambling) 

The Grand Jury further charges: 

73. From at least in or about 2008, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, DMITRY DRUZHINSKY, 

ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a 

"Murashka," and ARTHUR AZEN, the defendants, who were engaged in 

the business of betting and wagering, knowingly and willfully 

did accept, in connection with the participation of another 

person in unlawful Internet gambling, credit, and the proceeds 

of credit, extended to and on behalf of such other person 

(including credit extended through the use of a credit card); an 

electronic fund transfer, and funds transmitted by and through a 

money transmitting business, and the proceeds of an electronic 

fund transfer and money transmitting service, from and on behalf 

of such other person; a check, draft, and similar instrument 

which was drawn by and on behalf of such other person and was 

drawn on and payable at and through a financial institution; and 

the proceeds of another form of financial transaction, as the 

Secretary and the Board of Governors of the Federal Reserve 

System have prescribed by regulation, which involves a financial 

institution as a payor and financial intermediary on behalf of 

- 60 -and for the benefit of such other person, to wit, DRUZHINSKY, 

ZAVERUKHA, KATCHALOFF and AZEN, operated an illegal bookmaking 

business that utilized gambling websites operating illegally in 

the United States. 

(Title 31, United States Code, Sections 5363 and 5366; 
Title 18, United States Code, Section 2.) 

COUNT EIGHTEEN 

(Money Laundering Conspiracy) 

The Grand Jury further charges: 

74. From at least in or about 2008, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, DMITRY DRUZHINKSKY, 

ANATOLY GOLUBCHIK, a/k/a "Tony," ILYA ROZENFELD, and ANATOLY 

SHTEYNGRAB, the defendants, and others known and unknown, 

willfully and knowingly combined, conspired, confederated, and 

agreed together and with each other to violate Sections 1956 

(a) ( 1 ) (B) ( i ) , (a) ( 2 ) (A) , and (a) ( 2 ) (B) ( i ) , and 19 57 of Title 18 , 

United States Code, to wit, the defendants laundered millions of 

dollars in p~oceeds from DRUZHINSKY's sports gambling business 

through various companies including a real estate company in New 

York, New York, a car repair shop in Brooklyn, New York, and a 

company that sells used cars over the internet. 

75. It was a part and an object of the conspiracy 

that DMITRY DRUZHINKSKY, ANATOLY GOLUBCHIK, a/k/a "Tony," ILYA 

- 61 -



ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, and others 

known and unknown, knowing that the property involved in such 

financial transactions represented the proceeds of some form of 

unlawful activity, willfully and knowingly would and did conduct 

and attempt to conduct financial transactions which in fact 

involved the proceeds of specified unlawful activity, to wit, an 

illegal gambling business in violation of Title 18, United 

States Code, Sections 1955 and 1084, and New York Penal Law 

Section 225.10, knowing that such financial transactions were 

designed in whole and in part to conceal and disguise the 

nature, location, source, ownership and control of the proceeds 

of specified unlawful activity, in violation of Title 18, United 

States Code, Section 1956 (a) (1) (B) (i). 

76. It was further a part and an object of the 

conspiracy that DMITRY DRUZHINKSKY, ANATOLY GOLUBCHIK, a/k/a 

"Tony," ILYA ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, 

and others known and unknown, willfully and knowingly would and 

did transport, transmit, and transfer, and attempt to transport, 

transmit, and transfer a monetary instrument and funds from a 

place in the United States to and through a place outside the 

United States and to a place in the United States from and 

through a place outside the United States with the intent to 

promote the carrying on of a specified unlawful activity, to 

wit, an illegal gambling business in violation of Title 18, 

- 62 -



United States Code 1 Sections 1955 and 1084/ and New York Penal 

Law Section 225.10 1 all in violation of Title 18 1 United States 

Code 1 Section 1956 (a) (2) (A). 

77. It was further a part and an object of the 

conspiracy that DMITRY DRUZHINKSKY 1 ANATOLY GOLUBCHIK 1 a/k/a 

"Tony 1
11 ILYA ROZENFELD 1 and ANATOLY SHTEYNGRAB 1 the defendants/ 

and others known and unknown/ willfully and knowingly would and 

did transport/ transmit/ and transfer/ and attempt to transport/ 

transmit/ and transfer monetary instruments and funds from a 

place in the United States to and through a place outside the 

United States and to a place in the United States from and 

through a place outside the United States knowing that the 

monetary instruments and funds involved in the transportations/ 

transmissions/ and transfers represented the proceeds of some 

form of unlawful activity and knowing that such transportations/ 

transmissions/ and transfers were designed in whole and in part 

to conceal and disguise the nature/ the location/ the source/ 

the ownership/ and the control of the proceeds of a specified 

unlawful activity/ to wit 1 an illegal gambling business in 

violation of Title 18 1 United States Code/ Sections 1955 and 

1084 1 and New York Penal Law Section 225.10 1 all in violation of 

Title 18 1 United States Code/ Section 1956 (a) (2) (B) (i). 

78. It was further a part and an object of the 

conspiracy that DMITRY DRUZHINKSKY 1 ANATOLY GOLUBCHIK 1 a/k/a 

- 63 -



"Tony," ILYA ROZENFELD, and ANATOLY SHTEYNGRAB, the defendants, 

and others known and unknown, in an offense involving and 

affecting interstate and foreign commerce, would and did engage 

in and attempt to engage in monetary transactions, as that term 

is defined in Title 18, United States Code, Section 1957(f) (1), 

in criminally derived property that was of a value greater than 

$10,000, to wit, wire transfers in excess of $10,000 between 

bank accounts in Cyprus controlled by the defendants and bank 

accounts in the United States controlled by the defendants, such 

property having been derived from a specified unlawful activity, 

to wit, an illegal gambling business in violation of Title 18, 

United States Code, Sections 1955 and 1084, and New York Penal 

Law Section 225.10, all in violation of Title 18, United States 

Code, Section 1957. 

(Title 18, United States Code, Section 1956(h) .) 

COUNT NINETEEN 

(To Collect Extensions of Credit by Extortionate Means) 

The Grand Jury further charges: 

79. From at least in or about January 2012, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, ARTHUR AZEN, KIRILL 

RAPOPORT, and MOSHE ORATZ, the defendants, and others known and 

unknown, knowingly and willfully combined, conspired, 

- 64 -



confederated, and agreed together and with each other to 

participate in the use of extortionate means, as that term is 

defined in Title 18, United States Code, Section 891(7), to 

collect and attempt to collect extensions of credit, as that 

term is defined in Title 18, United States Code, Section 891(1), 

and to punish a person, to wit, gamblers who owed poker and/or 

sports gambling debts, for the nonrepayment thereof, to wit, 

AZEN, RAPOPORT, and ORATZ, agreed to use violence and threats of 

violence to collect sports and poker gambling debts from 

gamblers. 

(Title 18, United States Code, Section 894.) 

COUNT TWENTY 

(Illegal Poker Business) 

The Grand Jury further charges: 

80. From at least in or about 2010, up to and 

including on or about the date of this Indictment, in the 

Southern District of New York and elsewhere, EUGENE TRINCHER, 

EDWIN TING, a/k/a "Eddie," ARTHUR AZEN, JOSEPH MANCUSO, WILLIAM 

BARBALAT, YUGESHWAR RAJKUMAR, a/k/a "Mateo Hermatte," MOLLY 

BLOOM, the defendants, knowingly and willfully did conduct, 

finance, manage, supervise, direct, and own all and part of an 

illegal gambling business, as that term is defined in Title 18, 

United States Code, Section 1955 (b) (1), (2), and (3), and did 

- 65 -



aid and abet the same, to wit, TRINCHER, TING, AZEN, MANCUSO, 

BARBALAT, RAJKUMAR, and BLOOM, operated an illegal poker 

business which violated New York Penal Law Section 225.05, 

involved five or more persons who conducted, financed, managed, 

supervised, directed, and owned all or part of such business, 

and had been and remained in substantially continuous operation 

for a period in excess of thirty days and had a gross revenue of 

$2,000 in any single day. 

(Title 18, United States Code, Sections 1955 and 2.) 

COUNT TWENTY-ONE 

(Travel Act) 

The Grand Jury further charges: 

81. In or about December 2011, in the Southern 

District of New York and elsewhere, EUGENE TRINCHER, the 

defendant, intentionally and knowingly did travel in interstate 

and foreign commerce and use the mail and a facility in 

interstate and foreign commerce, with intent to distribute the 

proceeds of an unlawful activity, and to otherwise promote, 

manage, establish, carry on, and facilitate the promotion, 

management, establishment, and carrying on, of an unlawful 

activity, and thereafter did distribute and attempt to 

distribute the proceeds of an unlawful activity, and to 

otherwise promote, manage, establish, carry on, and facilitate 

- 66 -



the promotion, management, establishment, and carrying on, of an 

unlawful activity, to wit, TRINCHER caused a check in the amount 

of $10,000, issued in connection with operating an illegal poker 

game in New York City, to be deposited into a bank account in 

Connecticut. 

(Title 18, United States Code, Sections 1952 and 2.) 

COUNT TWENTY-TWO 

(Travel Act) 

The Grand Jury further charges: 

82. In or about November 2011, in the Southern 

District of New York and elsewhere, EDWIN TING, a/k/a "Eddie," 

the defendant, intentionally and knowingly did travel in 

interstate and foreign commerce and use the mail and a facility 

in interstate and foreign commerce, with intent to distribute 

the proceeds of an unlawful activity, and to otherwise promote, 

manage, establish, carry on, and facilitate the promotion, 

management, establishment, and carrying on, of an unlawful 

activity, and thereafter did distribute and attempt to 

distribute the proceeds of an unlawful activity, and to 

otherwise promote, manage, establish, carry on, and facilitate 

the promotion, management, establishment, and carrying on, of an 

unlawful activity, to wit, TING, deposited a check in the amount 

of $250,000 from a bank account in California into a bank 

- 67 -



account in New York, in connection with operating an illegal 

poker game in New York City. 

(Title 18, United States Code, Sections 1952 and 2.) 

COUNT TWENTY-THREE 

(Travel Act) 

The Grand Jury further charges: 

83. In or about March 2011, in the Southern District 

of New York and elsewhere, ARTHUR AZEN, the defendant, 

intentionally and knowingly did travel in interstate and foreign 

commerce and use the mail and a facility in interstate and 

foreign commerce, with intent to distribute the proceeds of an 

unlawful activity, and to otherwise promote, manage, establish, 

carry on, and facilitate the promotion, management, 

establishment, and carrying on, of an unlawful activity, and 

thereafter did distribute and attempt to distribute the proceeds 

of an unlawful activity, and to otherwise promote, manage, 

establish, carry on, and facilitate the promotion, management, 

establishment, and carrying on, of an unlawful activity, to wit, 

AZEN deposited a check from WILLIAM BARBALAT, the defendant, in 

the amount of $4,000 in a connection with operating an illegal 

- 68 -



poker game in New York City, which check cleared by interstate 

wire. 

(Title 18, United States Code, Sections 1952 and 2.) 

COUNT TWENTY-FOUR 

(Travel Act) 

The Grand Jury further charges: 

84. In or about February 2012, in the Southern 

District of New York and elsewhere, JOSEPH MANCUSO, the 

defendant, intentionally and knowingly did travel in interstate 

and foreign commerce and use the mail and a facility in 

interstate and foreign commerce, with intent to distribute the 

proceeds of an unlawful activity, and to otherwise promote, 

manage, establish, carry on, and facilitate the promotion, 

management, establishment, and carrying on, of an unlawful 

activity, and thereafter did distribute and attempt to 

distribute the proceeds of an unlawful activity, and to 

otherwise promote, manage, establish, carry on, and facilitate 

the promotion, management, establishment, and carrying on, of an 

unlawful activity, to wit, MANCUSO wrote a check in the amount 

of $30,000 in connection with operating an illegal poker game in 

New York City, which check was deposited into a bank account in 

Connecticut. 

(Title 18, United States Code, Sections 1952 and 2.) 

- 69 -



COUNT TWENTY-FIVE 

(Travel Act) 

The Grand Jury further charges: 

85. In or about March 2011, in the Southern District 

of New York and elsewhere, WILLIAM BARBALAT, the defendant, 

intentionally and knowingly did travel in interstate and foreign 

commerce and use the mail and a facility in interstate and 

foreign commerce, with intent to distribute the proceeds of an 

unlawful activity, and to otherwise promote, manage, establish, 

carry on, and facilitate the promotion, management, 

establishment, and carrying on, of an unlawful activity, and 

thereafter did distribute and attempt to distribute the proceeds 

of an unlawful activity, and to otherwise promote, manage, 

establish, carry on, and facilitate the promotion, management, 

establishment, and carrying on, of an unlawful activity, to wit, 

BARBALAT wrote a check to ARTHUR AZEN, the defendant, in the 

amount of $4,000 in a connection with operating an illegal poker 

game in New York City, which check cleared by interstate wire. 

(Title 18, United States Code, Sections 1952 and 2.) 

- 70 -



COUNT TWENTY-SIX 

(Travel Act) 

The Grand Jury further charges: 

86. In or about January 2011, in the Southern 

District of New York and elsewhere, YUGESHWAR RAJKUMAR, a/k/a 

"Mateo Hermatte," the defendant, intentionally and knowingly did 

travel in interstate and foreign commerce and use the mail and a 

facility in interstate and foreign commerce, with intent to 

distribute the proceeds of an unlawful activity, and to 

otherwise promote, manage, establish, carry on, and facilitate 

the promotion, management, establishment, and carrying on, of an 

unlawful activity, and thereafter did distribute and attempt to 

distribute the proceeds of an unlawful activity, and to 

otherwise promote, manage, establish, carry on, and facilitate 

the promotion, management, establishment, and carrying on, of an 

unlawful activity, to wit, RAJKUMAR wrote a check from his New 

Jersey bank account in the amount of $11,500 in connection with 

operating an illegal poker game in New York City. 

(Title 18, United States Code, Sections 1952 and 2.) 

- 71 -



COUNT TWENTY-SEVEN 

(Travel Act) 

The Grand Jury further charges: 

87. In or about June 2010, in the Southern District 

of New York and elsewhere, MOLLY BLOOM, the defendant, 

intentionally and knowingly did travel in interstate and foreign 

commerce and use the mail and a facility in interstate and 

foreign commerce, with intent to distribute the proceeds of an 

unlawful activity, and to otherwise promote, manage, establish, 

carry on/ and facilitate the promotion, management, 

establishment, and carrying on, of an unlawful activity, and 

thereafter did distribute and attempt to distribute the proceeds 

of an unlawful activity, and to otherwise promote, manage, 

establish, carry on/ and facilitate the promotion, management, 

establishment, and carrying on, of an unlawful activity, to wit, 

BLOOM deposited two checks totally $25,900 into a bank account 

in California in connection with operating an illegal poker game 

in New York City. 

(Title 18, United States Code, Sections 1952 and 2.) 

- 72 -



Forfeiture Allegation as to Counts One and Two 

(Taiwanchik-Trincher Organization) 

88. The allegations contained in Counts One and Two 

of this Indictment are hereby repeated, realleged, and 

incorporated by reference herein as though fully set forth at 

length for the purpose of alleging forfeiture pursuant to Title 

18, United States Code, Section 2461(c). 

89. Pursuant to Rule 32.2(a), Fed. R. Crim. P., 

ALIMZHAN TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM TRINCHER, 

a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, and 

STAN GREENBERG, a/k/a "Slava," the defendants, are hereby 

notified that, upon conviction of the violation or violations of 

Title 18, United States Code, Section 1962, in Counts One and 

Two the Indictment, the defendants shall forfeit, pursuant to 

Title 18, United States Code, Section 1963: 

a. all interests acquired and maintained in 

violation of Title 18, United States Code, Section 1962i 

b. all interests in, securities of, claims 

against, and property and contractual rights of any kind 

affording a source of influence over, the enterprise named and 

described herein which the defendants established, operated, 

controlled, conducted, and participated in the conduct of, in 

violation of Title 18, United States Code, Section 1962i and 

- 73 -



c. all property constituting and derived from 

proceeds obtained, directly and indirectly, from racketeering 

activity in violation of Title 18, United States Code, Section 

1962. 

90. The property subject to forfeiture to the United 

States pursuant to Title 18, United States Code, Section 

1963 (a) (1), (a) (2), and (a) (3), includes, but is not limited at 

least $50 million which represents the total of the interests 

acquired and the gross proceeds obtained through the violation 

of Title 18, United States Code, Section 1962, and the following 

specific property which constitutes and is derived from proceeds 

obtained, directly and indirectly, from racketeering activity in 

violation of Title 18, United States Code, Section 1962: 

a. 721-725 5th Avenue, Apartment 63A and B, New 

York, NY 10022; 

b. 971 Madison Avenue, Units SA, B and C, New 

York, NY 10021; 

c. 16001 Collins Avenue, Unit 806, Sunny Isles 

Beach, FL 33160; and 

d. 16001 Collins Avenue, Unit 1206, Sunny Isles 

Beach, FL 33160. 

91. Pursuant to Title 18, United States Code, Section 

1963(m), ALIMZHAN TOKHTAKHOUNOV, a/k/a "Alik Taiwanchik," VADIM 

TRINCHER, a/k/a "Dima," ANATOLY GOLUBCHIK, a/k/a "Tony," MICHAEL 

- 74 -



SALL, and STAN GREENBERG, a/k/a "Slava," the defendants, shall 

forfeit substitute property up to the value of the property 

described in the previous paragraph if that property, as a 

result of any act or omission of the defendants: 

a. cannot be located upon the exercise of due 

diligence; 

b. has been transferred or sold to, or 

deposited with, a third party; 

c. has been placed beyond the jurisdiction of 

this Court; 

d. has been substantially diminished in value; 

and 

e. has been commingled with other property 

which cannot be divided without difficulty. 

92. The above-named defendants are jointly and 

severally liable for the forfeiture allegations alleged above. 

(Title 18, United States Code, Section 1963.) 

Forfeiture Allegation as to Counts Three and Four 

(Nahmad-Trincher Organization) 

93. The allegations contained in Counts Three and 

Four of this Indictment are hereby repeated, realleged, and 

incorporated by reference herein as though fully set forth at 

- 75 -



length for the purpose of alleging forfeiture pursuant to Title 

18, United States Code, Section 2461(c). 

94. Pursuant to Rule 32.2(a), Fed. R. Crim. P., ILLYA 

TRINCHER, HILLEL NAHMAD, a/k/a "Helly," NOAH SIEGEL, a/k/a "The 

Oracle," JOHN HANSON, JONATHAN HIRSCH, ARTHUR AZEN, and DONALD 

MCCALMONT, the defendants, are hereby notified that, upon 

conviction of the violation or violations of Title 18, United 

States Code, Section 1962, as charged in Counts Three and Four 

of this Indictment, the defendants shall forfeit, pursuant to 

Title 18, United States Code, Section 1963: 

a. all interests acquired and maintained in 

violation of Title 18, United States Code, Section 1962; 

b. all interests in, securities of, claims 

against, and property and contractual rights of any kind 

affording a source of influence over, the enterprise named and 

described herein which the defendants established, operated, 

controlled, conducted, and participated in the conduct of, in 

violation of Title 18, United States Code, Section 1962; and 

c. all property constituting and derived from 

proceeds obtained, directly and indirectly, from racketeering 

activity in violation of Title 18, United States Code, Section 

1962. 

95. The property subject to forfeiture to the United 

States pursuant to Title 18, United States Code, Section 

- 76 -



1963 (a) (1) r (a) (2) r and (a) (3) r includes/ but is not limited at 

least $50 million which represents the total of the interests 

acquired and the gross proceeds obtained through the violation 

of Title 18 1 United States Coder Section 1962 1 which constitutes 

and is derived from proceeds obtained/ directly and indirectly/ 

from racketeering activity in violation of Title 18r United 

States Coder Section 1962. 

96. Pursuant to Title 18 1 United States Coder Section 

1963(m) 1 ILLYA TRINCHER 1 HILLEL NAHMAD 1 a/k/a "Helly 1
11 NOAH 

SIEGEL 1 a/k/a "The Oracle 1
11 JOHN HANSON 1 JONATHAN HIRSCH 1 ARTHUR 

AZEN 1 and DONALD MCCALMONT 1 the defendants/ shall forfeit 

substitute property up to the value of the property described in 

the previous paragraph if that property/ as a result of any act 

or omission of the defendants: 

a. cannot be located upon the exercise of due 

diligence; 

b. has been transferred or sold tor or 

deposited with/ a third party; 

c. has been placed beyond the jurisdiction of 

this Court; 

d. has been substantially diminished in value; 

and 

e. has been commingled with other property 

which cannot be divided without difficulty. 

- 77 -



97. The above-named defendants are jointly and 

severally liable for the forfeiture allegations alleged above. 

(Title 18, United States Code, Section 1963.) 

Forfeiture Allegation as to Counts Five, Eight, Nine, Ten, 
Fourteen, Fifteen, Sixteen, and Nineteen to Twenty-Seven 

98. As a result of committing the illegal gambling 

business, extortion, transmission of sports wagering 

information, travel act, and wire fraud offenses alleged in 

Counts Five, Eight, Nine, Ten, Fourteen, Fifteen, Sixteen, and 

Nineteen to Twenty-Seven of this Indictment, ALIMZHAN 

TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a "Alik," VADIM TRINCHER, 

a/k/a "Dima," and ANATOLY GOLUBCHIK, a/k/a "Tony," HILLEL 

NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH SIEGEL, a/k/a "The 

Oracle," JOHN HANSON, JONATHAN HIRSCH, JUSTIN SMITH, WILLIAM 

EDLER, PETER FELDMAN, MOSHE ORATZ, DAVID AARON, a/k/a "D.A. ," 

BRYAN ZURIFF, ABRAHAM MOSSERI, DMITRY DRUZHINSKY, ALEXANDER 

ZAVERUKHA, a/k/a "Sasha," ALEXANDER KATCHALOFF, a/k/a 

"Murashka," ARTHUR AZEN, KIRILL RAPOPORT, MOSHE ORATZ, EUGENE 

TRINCHER, EDWIN TING, a/k/a "Eddie," JOSEPH MANCUSO, WILLIAM 

BARBALAT, YUGESHWAR RAJKUMAR, a/k/a "Mateo Hermatte," MOLLY 

BLOOM, the defendants, shall forfeit to the United States 

pursuant to Title 18, United States Code, Section 981(a) (1) (C) 

and Title 28, United States Code, S.ection 2461, any and all 

- 78 -



property constituting, and derived from, proceeds obtained 

directly and indirectly as a result of such violations. 

99. As a result of the illegal gambling business 

offenses alleged in Counts Five, Nine, Sixteen and Twenty of 

this Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," 

a/k/a "Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY 

GOLUBCHIK, a/k/a "Tony," HILLEL NAHMAD, a/k/a "Helly," ILLYA 

TRINCHER, NOAH SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN 

HIRSCH, JUSTIN SMITH, WILLIAM EDLER, PETER FELDMAN, MOSHE ORATZ, 

DAVID AARON, a/k/a "D.A.," BRYAN ZURIFF, ABRAHAM MOSSERI, DMITRY 

DRUZHINSKY, ALEXANDER ZAVERUKHA, a/k/a "Sasha," ALEXANDER 

KATCHALOFF, a/k/a "Murashka," ARTHUR AZEN, KIRILL RAPOPORT, 

MOSHE ORATZ, EUGENE TRINCHER, EDWIN TING, a/k/a "Eddie," JOSEPH 

MANCUSO, WILLIAM BARBALAT, YUGESHWAR RAJKUMAR, a/k/a "Mateo 

Hermatte," MOLLY BLOOM, the defendants, shall forfeit to the 

United States pursuant to Title 18, United States Code, Section 

1955(d), any property, including money, used in such violations. 

Substitute Asset Provision 

100. If any of the above-described forfeitable 

property, as a result of any act or omission of the defendants: 

a. cannot be located upon the exercise of due 

diligence; 

b. has been transferred or sold to, or 

deposited with, a third person; 

- 79 -



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 (p), to seek forfeiture of any 

other property of said defendants up to the value of the above-

described forfeitable property. 

(Title 18, United States Code, Section 981 and 1955; 
Title 21, United States Code, Section 853; 

and Title 28, United States Code, Section 2461.) 

Forfeiture Allegation as to Counts Seven, Twelve, and Eighteen 

101. As a result of committing the money laundering 

offenses alleged in Counts Seven, Twelve, Eighteen of this 

Indictment, ALIMZHAN TOKHTAKHOUNOV, a/k/a "Taiwanchik," a/k/a 

"Alik," VADIM TRINCHER, a/k/a "Dima," and ANATOLY GOLUBCHIK, 

a/k/a "Tony," HILLEL NAHMAD, a/k/a "Helly," ILLYA TRINCHER, NOAH 

SIEGEL, a/k/a "The Oracle," JOHN HANSON, JONATHAN HIRSCH, DMITRY 

DRUZHINSKY, ALEXANDER ZAVERUKHA, a/k/a "Sasha," EUGENE TRINCHER, 

EDWIN TING, a/k/a "Eddie," PETER SKYLLAS, RONALD UY, DON 

MCCALMONT, ILYA ROSENFELD, and ANATOLY SHTEYNGRAB, the 

defendants, shall forfeit to the United States pursuant to Title 

- 80 -18, United States Code, Section 982(a) (1), any property, real or 

personal, involved in such offense, or any property traceable to 

such property. 

Substitute Asset Provision 

102. If any of the above-described forfeitable 

property, as a result of any act or omission of the defendants: 

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(p), to seek forfeiture of any 

other property of said defendants up to the value of the above-

described forfeitable property. 

(Title 18, United States Code, Section 982; 
and Title 21, United States Code, Section 853.) 

Forfeiture Allegation as to Count Thirteen 

- 81 -



103. As a result of committing the structuring offense 

alleged in Count Thirteen of this Indictment, RONALD UY and 

ILLYA TRINCHER, the defendants, shall forfeit to the United 

States pursuant to Title 31, United States Code, Section 

5317(c), all property, real or personal, involved in such 

offense, or any property traceable to such property. 

Substitute Asset Provision 

104. If any of the above-described forfeitable 

property, as a result of any act or omission of the defendants: 

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(p), to seek forfeiture of any 

- 82 -



other property of said defendants up to the value of the above-

described forfeitable property. 

(31, United States Code, Section 5317(c); and 
Title 21, United States Code, Section 853.) 

PREET BHARARA 
United States Attorney 

- 83 -



UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 
- v. -

ALIMZHAN TOKHTAKHOUNOV, a/k/a 
"Taiwanchik," a/k/a "Alik," VADIM 

TRINCHER, a/k/a "Dima," ANATOLY 
GOLUBCHIK, a/k/a "Tony," MICHAEL SALL, 

STAN GREENBERG, a/k/a "Slava," ILLYA 
TRINCHER, HILLEL NAHMAD, a/k/a "Helly," 

JOHN HANSON, NOAH SIEGEL, a/k/a "The 
Oracle," JONATHAN HIRSCH, ARTHUR AZEN, 

DONALD MCCALMONT, DMITRY DRUZHINSKY, 
a/k/a "Dima," a/k/a "Blondie," ALEXANDER 

ZAVERUKHA, a/k/a "Sasha," ALEXANDER 
KATCHALOFF, a/k/a "Murushka," ANATOLY 

SHTEYNGROB, a/k/a "Tony," ILYA 
ROZENFELD, PETER SKYLLAS, RONALD UY, 
NICHOLAS HIRSCH, BRYAN ZURIFF, MOSHE 
ORATZ, KIRILL RAPOPORT, DAVID AARON, 
a/k/a "D.A.," JUSTIN SMITH, ABRAHAM 

MOSSERI, WILLIAM EDLER, PETER FELDMAN, 
EUGENE TRINCHER, EDWIN TING, a/k/a 

"Eddie," MOLLY BLOOM, WILLIAM BARBALAT, 
YUGESHWAR RAJKUMAR, a/k/a "Mateo 

Hermatte," and JOSEPH MANCUSO,a/k/a "Joe 
the Hammer," 

Defendants. 

SEALED INDICTMENT 

13 Cr. 

(18 u.s.c. §§ 894, 1084, 1951, 1952, 
1955, 1956, 1962, and 2; 

31 U.S.C. §§ 5324, 5363, and 5366.) 

PREET BHARARA 

United States A~torney. 
/ 

son.