Indictment — United States v. Adepoju Babatunde Salako, District of Colorado (Document 1)
Summary
An Indictment filed May 20, 2025 as Document 1 in United States v. Adepoju Babatunde Salako, Criminal Case No. 25-cr-162-CNS, in the United States District Court for the District of Colorado. Count 1 (Conspiracy to Commit Wire Fraud) alleges that from in or about March 2020 through in or about September 2021 Salako and CONSPIRATOR 1 agreed to commit wire fraud in violation of Title 18, United States Code, Section 1343, and requested CARES Act funding of over $700,000, of which they obtained approximately $73,506.16. The indictment describes unemployment insurance, PPP and EIDL programs as background and includes forfeiture allegations, including for Count 8 under 18 U.S.C. § 1956(h). The signature block names Acting United States Attorney J. Bishop Grewell and Assistant U.S. Attorney Craig G. Fansler.
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“Indictment — United States v. Adepoju Babatunde Salako, District of Colorado (Document 1).”
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Case No. 1:25-cr-00162-CNS Document 1 filed 05/20/25 USDC Colorado pg 1
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Criminal Case No. 25-cr-162-CNS
UNITED STATES OF AMERICA,
Plaintiff,
v.
1. ADEPOJU BABATUNDE SALAKO,
Defendant.
INDICTMENT
The Grand Jury charges:
COUNT 1
Conspiracy to Commit Wire Fraud
At all times material to this Indictment:
Individuals and Entities
1. Defendant ADEPOJU BABATUNDE SALAKO was a resident of the
State and District of Pennsylvania.
2. SALAKO was the sole owner of Tudor Smart Phones & Accessories
LLC (“Tudor”), a Pennsylvania-registered limited liability company
3. CONSPIRATOR 1, whose identity is known to the Grand Jury, resided
in Nigeria.
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Background on Pandemic Benefit Programs
4. Unemployment Insurance (“UI”) is a joint state-federal program that
provides monetary benefits to eligible lawful workers. UI benefits are intended to
provide temporary financial assistance to lawful workers who become unemployed
through no fault of their own. Claimants seeking UI benefits are required to
complete an online application that includes, among other things, the claimant’s
name, date of birth, social security number, and the reason why the claimant is
unemployed. In the State of Colorado, the Colorado Department of Labor and
Employment (“CDLE”) administers the UI program. The CDLE, like other state
workforce agencies, relies upon the information in the application to determine UI
benefits eligibility. If the CDLE approves a UI claim, the claimant can receive UI
benefits by direct deposit.
5. In March 2020, the Coronavirus Aid, Relief, and Economic Security
(“CARES”) Act was enacted. It expanded UI benefits by providing additional federal
funding and provided emergency assistance to small business owners suffering
adverse economic effects caused by the COVID-19 pandemic. It also provided
funding for small businesses affected by the COVID-19 pandemic through the
Paycheck Protection Program (“PPP”) and the Economic Injury Disaster Loan
(“EIDL”) program, each administered by the United States Small Business
Administration (“SBA”).
6. To receive federal money for UI benefits after passage of the CARES
Act, the CDLE had to request money from the United States Department of the
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Treasury (“Treasury”) through a Treasury web interface program. To request
federal funds, the CDLE made a payment request to Treasury, and Treasury would
then disburse the funds to the CDLE’s bank account.
7. The EIDL program is an SBA program that provides low-interest
financing to small businesses in regions affected by declared disasters. During the
COVID-19 pandemic, qualifying businesses affected by the pandemic could obtain
an EIDL by submitting an application to the SBA and providing information about
operations prior to January 31, 2020, including its number of employees, revenues,
and cost of goods sold. The amount of the loan, if approved, was determined in part
based on the information provided concerning the gross revenue and cost of goods
sold. EIDL and EIDG funds were issued directly by the SBA. Until April 2021,
under the EIDL program, a small business could receive a loan from the SBA in an
amount of up to six months of working capital with a maximum of $150,000. In
addition, the CARES Act authorized the SBA to issue advances of up to $10,000 to
small businesses, known as Economic Injury Disaster Grants (“EIDG”). Initially,
the amount of the EIDG was determined by the number of employees the applicant
certified having. The EIDGs did not need to be repaid.
8. The PPP provided forgivable loans to small businesses. To obtain a
PPP loan, a qualifying small business was required to submit a PPP loan
application signed by an authorized representative of the business and to make
affirmative certifications, including that the information in the application and
supporting documents was true and accurate. The amount of the loan was
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calculated based on a business’s representations about its monthly payroll
expenses. Businesses were also required to provide documentation showing their
payroll expenses, such as filed federal income tax documents. PPP loan applications
were received and processed, in the first instance, by a participating lender. If a
PPP loan application was approved, the participating lender funded the loan using
its own money, but the loans were guaranteed by the SBA. Data from the
application, including information about the borrower, the total amount of the loan,
and the listed number of employees, was transmitted by the lender to the SBA in
the course of processing the loan. The SBA paid participating lenders a processing
fee from its Colorado finance center for each funded PPP loan.
The Conspiracy
9. From in or about March 2020 through in or about September 2021, in
the District of Colorado and elsewhere, defendant ADEPOJU BABATUNDE
SALAKO and CONSPIRATOR 1, together and with each other, knowingly agreed to
commit wire fraud, in violation of Title 18, United States Code, Section 1343.
Manner and Means of the Scheme and Conspiracy
Acting interdependently, SALAKO and CONSPIRATOR 1 carried out the
conspiracy using the following manner and means:
10. After the CARES Act authorized EIDL and PPP funding and expanded
federal funding for UI benefits, SALAKO and CONSPIRATOR 1 acted together to
request CARES Act funding of over $700,000. They obtained approximately
$73,506.16.
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11. SALAKO and CONSPIRATOR 1 used the WhatsApp messaging
service to exchange messages, documents, and information about the conspiracy,
including to exchange stolen or false identities and to share bank account details for
use on fraudulent applications.
12. SALAKO and CONSPIRATOR 1 used an email forwarding service
known as 33mail to create multiple usernames on custom email domains. Although
the email addresses appeared to be unique and refer to different individuals, 33mail
allowed all the usernames on the same domain to forward emails to the same email
address. As one example, SALAKO used multiple usernames on the
tudor31620.33mail.com domain, but all usernames on this domain forwarded to one
of SALAKO’s gmail accounts.
13. Along with submitting his own fraudulent applications for UI benefits,
SALAKO aided and abetted CONSPIRATOR 1 by sharing SALAKO’s bank account
numbers, phone number, and other identifiers with CONSPIRATOR 1.
CONSPIRATOR 1 then would list SALAKO’s information on fraudulent loan and
UI benefit applications.
14. To conceal that CONSPIRATOR 1 was located overseas, SALAKO’s
United States-based bank accounts and contact information was used on
applications, which created the false appearance to lenders or state workforce
agencies that CONSPIRATOR 1 was located in the United States and eligible for
government benefits.
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UI Benefit Scheme and Conspiracy
15. Between January 4, 2021 and March 20, 2021, SALAKO submitted
approximately 15 fraudulent applications for UI benefits to the CDLE, using stolen
or false identities.
a. SALAKO subscribed to personal information search websites
such as TruthFinder. Before submitting fraudulent applications
to the CDLE for UI benefits, SALAKO looked up names and
addresses of residents of Colorado so he could submit
applications using their actual identifiers.
b. Approximately 10 of SALAKO’s UI claims listed as a contact
email a username linked to the tudor31620.33mail.com email
domain that appeared to be separate emails, but which were
configured through the 33mail service to forward to a single
gmail account. Three other claims used a different 33mail.com
email domain used by SALAKO that forwarded to another email
account he monitored.
c. The CDLE paid one UI claim submitted by SALAKO. On March
3, 2021, the CDLE paid $649 to a Discover Bank account
controlled by SALAKO based on a fraudulent UI claim SALAKO
submitted using the stolen identity of V.H.
d. Other claims were approved for payment, including a claim
SALAKO submitted using the stolen identity of M.M. for $890,
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but the CDLE placed a payment hold after discovering that the
name on the bank account did not match the name on the UI
claim.
16. Between January 24, 2021 and May 19, 2021, CONSPIRATOR 1
submitted at least 54 fraudulent applications for UI benefits to the CDLE, using
stolen or false identities and directing that the CDLE deposit payments to accounts
controlled by SALAKO. The CDLE approved 7 of these fraudulent claims and paid
$15,431 in UI benefits to SALAKO-controlled bank accounts.
17. SALAKO and CONSPIRATOR 1 acted for their mutual benefit by
coordinating fraudulent activity. They exchanged bank account numbers, updated
each other about the status of claims, and coordinated the deposit and transfer of
fraud proceeds. For example:
a. On February 17, 2021, CONSPIRATOR 1 messaged SALAKO
that he would direct the CDLE to deposit UI benefits to a bank
account in SALAKO’s name. SALAKO agreed to receive the
funds. After the CDLE paid $949 to SALAKO’s bank account on
February 22, 2021, CONSPIRATOR 1 messaged SALAKO
“Colorado don dey payyy!!!”
b. On March 14, 2021, SALAKO messaged CONSPIRATOR 1 to
work together on a UI claim. SALAKO messaged a bank account
number created using the stolen identity of C.W. to
CONSPIRATOR 1. CONSPIRATOR 1 then submitted a CDLE
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claim using a stolen identity of L.H. The CDLE approved the UI
claim for L.H. and direct deposited $598 to the bank account in
the name of C.W. on March 15, 2021.
18. In addition to submitting fraudulent UI claims to Colorado, SALAKO
submitted fraudulent UI claims in other states using stolen or false identities,
including Maryland, Minnesota, New Hampshire, and New York. He received
approximately $26,801.16 from other states.
19. The submission of fraudulent UI claims by SALAKO and
CONSPIRATOR 1 caused a server used by the CDLE located outside of Colorado to
transmit wires to Colorado, which led CDLE employees to mail letters to the
addresses associated with the UI claims.
EIDL Scheme and Conspiracy
20. Between January 16, 2021 and March 3, 2021, SALAKO submitted
and aided and abetted in the submission of at least 10 fraudulent applications for
EIDLs to the SBA, using stolen or false identities. The applications requested loans
totaling approximately $287,422.50. The SBA did not approve any of these
applications.
21. Between January 26, 2021 and April 26, 2021, CONSPIRATOR 1
submitted and aided and abetted in the submission of at least 3 fraudulent
applications for EIDLs to the SBA, using stolen or false identities. CONSPIRATOR
1 listed a phone number and bank account belonging to SALAKO on each
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application. The applications requested loans totaling $450,000. The SBA did not
approve any of these applications.
PPP Loan Scheme and Conspiracy
22. On February 11, 2021, CONSPIRATOR 1 submitted a fraudulent PPP
loan application in the name of Turn-Turn-Turn Woodturning using the stolen
identity of D.P., a resident of Nevada. The application listed a bank account and
phone number belonging to SALAKO and a 33mail.com email address that routed
to a gmail account used by CONSPIRATOR 1. The application provided false
information about the identity of the person submitting the application and the
business’s operations. On February 12, 2021, a lender approved the application
based on the false representations and disbursed $30,625 to a Discover Bank
account in the name of SALAKO.
23. The disbursement of the PPP loan to SALAKO caused the SBA’s
finance center in Denver, Colorado to transmit a payment file outside of Colorado
for an associated lender processing fee.
All in violation of Title 18, United States Code, Section 1349.
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COUNTS 2-7
Wire Fraud and Aiding and Abetting Wire Fraud
The Scheme to Defraud
24. Beginning in or about January 2021 and continuing through in or
about May 2021, within the State and District of Colorado and elsewhere, defendant
ADEPOJU BABATUNDE SALAKO and CONSPIRATOR 1 together and with each
other, devised, intended to devise, and participated in a scheme to defraud and to
obtain money and property from the CDLE, the Small Business Administration,
and private lenders by means of materially false and fraudulent pretenses,
representations, and promises, and aided and abetted the same.
Manner and Means of the Scheme
25. Paragraphs 1-8 and 10-23 are re-alleged and incorporated as if fully
set forth herein.
Execution of the Scheme
26. On or about the dates set forth below, in the State and District of
Colorado, and elsewhere, SALAKO transmitted and caused to be transmitted by
means of wire communication in interstate commerce certain writings, signs,
signals, pictures, and sounds, as set forth below:
Count Date Description of Wire
2 01/25/2021 Request for payment routed from Colorado to Treasury web
interface outside Colorado caused by fraudulent submission
of V.H. UI claim
3 2/24/2021 Request for payment routed from Colorado to Treasury web
interface outside Colorado caused by fraudulent submission
of N.B. UI claim
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4 2/25/2021 Wire from server outside of Colorado to CDLE employee in
Colorado related to claim notification letter mailed to D.B.
5 3/4/2021 Request for payment routed from Colorado to Treasury web
interface outside Colorado caused by fraudulent submission
of N.B. UI claim
6 3/6/2021 Request for payment routed from Colorado to Treasury web
interface outside Colorado caused by fraudulent submission
of L.H. UI claim
7 3/12/2021 Request for payment routed from Colorado to Treasury web
interface outside Colorado caused by fraudulent submission
of L.H. UI claim
All in violation of Title 18, United States Code, Sections 1343 and 2(a).
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COUNT 8
Money Laundering Conspiracy, 18 U.S.C. § 1956(h)
27. Paragraphs 1-8 are re-alleged and incorporated as if fully set forth
herein.
28. Beginning in or about July 2020, and continuing thereafter until in or
about July 2021, in the State and District of Colorado and elsewhere, defendant
ADEPOJU BABATUNDE SALAKO knowingly combined, conspired, and agreed
with co-conspirators known and unknown to the Grand Jury to:
a. knowingly conduct and attempt to conduct financial
transactions affecting interstate commerce that involved the
proceeds of specified unlawful activity, that is, wire fraud in
violation of 18 U.S.C. § 1343, knowing that the transaction was
designed in whole or in part to conceal and disguise the nature,
location, source, ownership, and control of the proceeds of
specified unlawful activity and that while conducting and
attempting to conduct such financial transactions knew that the
property involved in the financial transactions represented the
proceeds of some form of unlawful activity, in violation of 18
U.S.C. § 1956(a)(1)(B)(i).
b. knowingly engage or attempt to engage in monetary
transactions, as defined in Title 18, United States Code, Section
1957(f)(1), in criminally derived property of a value greater than
$10,000 and that was derived from specified unlawful activity,
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to wit, a scheme to commit wire fraud in violation of 18 U.S.C.
§ 1343, in violation of 18 U.S.C. § 1957(a).
Manner and Means of the Conspiracy
Acting interdependently, SALAKO and other conspirators known and
unknown carried out the conspiracy using the following manner and means:
29. SALAKO’s co-conspirators applied for EIDL, PPP, and UI funding
using stolen or fake identities. As a result of fraudulent applications, SALAKO’s co-
conspirators obtained approximately $4,711,200 in EIDL funding and $893,771.34
in UI funding. To obtain this funding, co-conspirators submitted EIDL applications
using over 1,000 stolen or fake identities and submitted fraudulent UI benefit
claims to approximately 30 different states.
30. All EIDL payments originated from an SBA finance center in Denver,
Colorado. SALAKO and his co-conspirators directed the movement of this money
from Colorado to bank accounts in multiple states outside of Colorado.
31. SALAKO’s co-conspirators fraudulently obtained approximately
$61,423 in UI benefits from the CDLE after submitting approximately 143
fraudulent UI benefit claims. SALAKO provided his bank account information to co-
conspirators so that they could direct CDLE to deposit funds directly to SALAKO’s
accounts.
32. SALAKO and co-conspirators exchanged with each other bank account
information, including some bank accounts in SALAKO’s name and others opened
by SALAKO using stolen and fake identities.
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33. After the initial deposit of fraud proceeds in a bank account, SALAKO
and co-conspirators would move fraud proceeds through several intermediate
accounts using various methods, including ATM withdrawals and deposits, wire
transfers, and the purchase and deposit of money orders.
34. Eventually, after conducting transfers through intermediate accounts,
SALAKO and co-conspirators spent fraud proceeds or transferred the money
overseas as currency or in the form of goods purchased from the fraud proceeds,
such as cars or solar panels.
35. Co-conspirators also shared in common victims of romance fraud
schemes who received fraud money from government agencies and sent to SALAKO
and other co-conspirators. The involvement of the romance fraud victims added an
additional layer to conceal the involvement of SALAKO and the co-conspirators. In
such instances, fraud money was initially deposited into accounts belonging to
victims of a romance fraud scheme—including P.B. and J.Y.—who were directed to
move fraud proceeds to SALAKO and co-conspirators.
36. A romance fraud scheme is a type of scheme by which a scammer
targets persons looking for partners or friendship on dating websites and other
social media platforms. The scammer may create profiles using fictitious or fake
names, locations, images, and personas, allowing the scammer to cultivate
relationships with prospective romance fraud scheme victims. Victims may be asked
to conduct financial transactions on behalf of the scammer, such as transferring
fraud proceeds to conceal the source or destination of the proceeds.
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c. Romance-fraud victim J.Y. received approximately $452,300 in
EIDL funds and $43,045 in UI benefits to bank accounts in his
own name.
d. Romance-fraud victim P.B. received approximately $301,400 in
EIDL funds, $17,700 in PPP funds, and $7,410 in UI benefits to
bank accounts in his name.
37. On applications for EIDL, PPP, and UI funding, multiple co-
conspirators designated that lenders or government agencies deposit fraud money
into bank accounts belonging to J.Y. and P.B.
38. After J.Y. and P.B. obtained fraud money, they received instructions to
initiate wire transfers and endorse checks and money orders to SALAKO’s business
(Tudor). For example:
a. Between June 30, 2020, and July 29, 2020, the SBA made four
deposits to J.Y.’s bank account for a total of $452,300 based on
four fraudulent EIDL applications submitted using stolen or
fake identities. J.Y. was instructed to make cash withdrawals,
purchase money orders, and transfer money to Tudor via wire
transfer or cashier’s check. J.Y. sent messages to confirm when
he completed an instruction. Between July 16, 2020, and August
10, 2020, J.Y. sent three cashier’s checks via mail endorsed to
Tudor (totaling $105,000) and two $15,000 wires to a Tudor
bank account.
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b. Between July 2, 2020, and August 10, 2020, the SBA made three
deposits to P.B.’s bank account for a total of $301,400 based on
three fraudulent EIDL applications submitted using stolen or
fake identities. P.B. was instructed to purchase money orders
and cashier’s checks and send the money orders and cashier’s
checks to Tudor via mail. Between July 25, 2020, and August 29,
2020, P.B. sent one money order and six cashier’s checks
endorsed to Tudor via mail, totaling $264,504.
c. On March 26, 2021, Cross River Bank deposited $17,708 to
P.B.’s bank account. The deposit related to a fraudulent PPP
loan submitted in the name of identity-theft victim J.B. on or
about March 25, 2021. P.B. obtained a teller check for $17,700
payable to Tudor. On April 13, 2021, SALAKO deposited this
check to a Tudor checking account.
39. After SALAKO received money that passed through the bank accounts
of romance-fraud victims, he conducted frequent transactions to move the money to
his personal accounts and conceal the source, nature, location, and destination of
the fraud proceeds.
40. It was part of the conspiracy that SALAKO made multiple cash
withdrawals from ATMs and branch locations on the same day or on dates in close
proximity and wired money between multiple business and personal bank accounts
he controlled.
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41. After making cash withdrawals from Tudor bank accounts, it was part
of the conspiracy that Salako would deposit the cash to personal bank accounts in
his own name, often on the same or consecutive days as the initial withdrawal from
his business bank account. From his personal bank accounts, SALAKO then
initiated wire transfers to China, Nigeria, and the United Arab Emirates. Between
July 20, 2020 and November 25, 2020, for example, SALAKO wired approximately
$932,881 of fraud proceeds from his personal Bank of America account ending in
3033 overseas to these three countries, as well as approximately $30,000 from his
other bank accounts.
42. After receiving one $40,000 cashier’s check from J.Y., SALAKO
explained why he moved the money between bank accounts through multiple
transactions over several days rather than withdrawing all the money at once in a
single transaction: “I don’t withdraw whole 40k just like that. I don’t do thing rush
rush rush rush rush” because it would “raise red flag.” Instead, SALAKO stated
that he did “things clean, slow.”
43. For his role of laundering fraud proceeds for co-conspirators operating
overseas, SALAKO took fees from the money he laundered, typically between 25-
60% of the value of laundered funds. For example, on July 16, 2020, when
discussing receiving fraud proceeds from J.Y., SALAKO messaged a conspirator
that his fee was 25 percent of laundered funds.
44. SALAKO and his conspirators also spent fraud proceeds to carry on
and engage in additional fraud, such as using fraud proceeds to pay phone bills for
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numbers used to facilitate fraud, pay subscriptions for personal information search
websites such as TruthFinder, and pay subscriptions for email accounts used to
facilitate the fraud, including the 33mail.com email domain.
45. SALAKO and his co-conspirators caused acts in furtherance of the
money-laundering conspiracy to take place in Colorado. For example, co-
conspirators provided the CDLE with Salako’s bank accounts in the United States
rather than their own to conceal and disguise the nature, location, source,
ownership, and control of their wire-fraud proceeds, including to conceal that the
fraud was committed from overseas and that fraud proceeds were eventually
transmitted overseas. Co-conspirators also provided the SBA with bank accounts
belonging to victims of romance-fraud rather than their own bank accounts for the
SBA to wire money from Colorado to those bank accounts outside of Colorado to
conceal and disguise the nature, location, source, ownership, and control of their
wire-fraud proceeds.
All in violation of Title 18, United States Code, Section 1956(h).
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COUNTS 9-12
Aggravated Identity Theft, 18 U.S.C. § 1028A
46. On or about the dates listed below, in the District of Colorado and
elsewhere, defendant ADEPOJU BABATUNDE SALAKO knowingly transferred,
possessed, and used, without lawful authority, a means of identification of the below
persons during and in relation to a felony violation enumerated in 18 U.S.C.
§ 1028A(c), to wit, wire fraud in violation of 18 U.S.C. § 1343 and conspiracy to
commit wire fraud in violation of 18 U.S.C. § 1349, knowing that the means of
identification belonged to another actual person.
COUNT DATE PERSON
9 01/27/2021 V.H., a Colorado resident
10 02/18/2021 M.C.., a Kansas resident
11 2/24/2021 M.M., a Colorado resident
12 03/15/2021 C.W., a New Hampshire resident
All in violation of Title 18, United States Code, Section 1028A(a)(1).
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FORFEITURE
47. Upon conviction of any of the violations alleged in Counts 1-7 of this
Indictment involving the commission of violations of 18 U.S.C. §§ 1343 and
1349, SALAKO shall forfeit to the United States, pursuant to 18 U.S.C.
§ 981(a)(1)(C) and 28 U.S.C. § 2461(c), any and all rights, title, and interest in all
property constituting and derived from any proceeds obtained directly and
indirectly as a result of such offense or offenses, including, but not limited to a
money judgment in the amount of the proceeds obtained by the defendant’s scheme.
48. Upon conviction of the violations alleged in Count 8 of this Indictment,
in violation of 18 U.S.C. § 1956(h), SALAKO shall forfeit to the United States,
pursuant to 18 U.S.C. § 982(a)(1), any and all rights, title, and interest in all
property involved in the offense and any property traceable to such property,
including, but not limited to a money judgment in the amount of value of the
property involved in the offense.
49. If any of the property described above, as a result of any act or
omission of SALAKO cannot be located upon the exercise of due diligence; has been
transferred or sold to, or deposited with, a third party; has been substantially
diminished in value; or has been commingled with other property that cannot be
divided without difficulty, it is the intent of the United States, pursuant to 28
U.S.C. § 2461(c), incorporating 21 U.S.C. § 853(p), to seek forfeiture of any other
property of SALAKO up to the value of the forfeitable property described above.
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A TRUE BILL:
Ink Signature on File in Clerk’s Office
FOREPERSON
J. BISHOP GREWELL
Acting United States Attorney
By: s/ Craig G. Fansler___________
Craig G. Fansler
Assistant U.S. Attorney
U.S. Attorney’s Office
1801 California St., Ste. 1600
Denver, CO 80202
Telephone: 303-454-0100
Fax: 303-454-0401
E-mail: Craig.Fansler2@usdoj.gov
Attorney for the United States
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