Information — United States v. Constantin Bobi Sandu, Southern District of California (Document 22)

Summary

An Information filed March 28, 2023 as Document 22 in United States v. Constantin Bobi Sandu, aka Bobi Sandu, aka Ionut Mihai, aka Constantin Sandu, Case No. 23cr386-LAB, in the U.S. District Court for the Southern District of California, dated 3/16/2023. Count 1 charges conspiracy to commit wire fraud under Title 18, U.S.C. § 1349 from in or about September 2020 to in or about August 2022. Count 2 charges conspiracy under Title 18 U.S.C. § 1956(h) to transport funds from the United States to a place outside the United States to promote the wire fraud conspiracy. The forfeiture allegations seek a money judgment equal to the proceeds and property involved in the laundering offense, and the Information lists United States Attorney Randy S. Grossman and Assistant U.S. Attorney Jessica Adeline Schulberg.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors.

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 3:23-cr-00386-LAB Document 22 Filed 03/28/23. PagelD.96 Pagelof3

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Case No, 23cr386-LAB
23MJ0697-AHG
Plaintiff, INFORMATION

Title 18, U.S.C. § 1349 -

v Conspiracy to Commit Wire
Fraud;
CONSTANTIN BOBI SANDU,
aka Bobi Sandu,
aka Ionut Mihai, Title 18 U.S.C. § 1956(h))-
aka Constantin Sandu, Conspiracy to Launder Monetary
Instruments;

Defendant.
Title 18 U.S.C. §§ 981 (a) (1) (C)
and 982(a) (1), and Title 28,
U.S.C. § 2461(c)- Criminal
Forfeiture

The United States Attorney charges:

Count 1

Beginning in or about September 2020, and continuing to in or about
August 2022, in the Southern District of California, and elsewhere,
Defendant CONSTANTIN BOBI SANDU, Aka Bobi Sandu, Aka Ionut Mihai, Aka
Constantin Sandu, knowingly and intentionally conspired and agreed with
other persons known and unknown, to commit wire fraud in violation of
Title 18, United States Code, Section 1343; all in violation of United
States Code Section 1349.

JSCH:San Diego
3/16/23
10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 3:23-cr-00386-LAB Document 22 Filed 03/28/23. PagelD.97 Page2of3

Count 2

Beginning in or about September 2020, and continuing to in or about
August 2022, in the Southern District of California, and elsewhere,
Defendant CONSTANTIN BOBI SANDU, Aka Bobi Sandu, Aka Ionut Mihai, Aka
Constantin Sandu, knowingly conspired and agreed with other persons
known and unknown, to commit the following money laundering offense: to
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 with the intent
to promote the carrying on of specified unlawful activity, that is
violations of Conspiracy to Commit Wire Fraud in violation of 18 U.S.C.
§ 1349; all in violation of Title 18, United States Code, Section
1956 (a) (2) (A).

All in violation of Title 18, United States Code, Section 1956(h).

Criminal Forfeiture Allegations

1. The allegations contained in Counts 1 and 2 are re-alleged and
incorporated by reference for the purpose of alleging forfeiture
pursuant to Title 18, United States Code, Sections 981(a)(1)(C) and
982(a) (1) and Title 28, United States Code, Section 2461(c).

2. Upon conviction of the offense in violation of Title 18,
United States Code, § 1349 set forth in Count 1 of this Information,
defendant, CONSTANTIN BOBI SANDU, aka Bobi Sandu, aka Ionut Mihai, aka
Constantin Sandu, shall forfeit to the United States of America, pursuant
to Title 18, United States Code, Section 981(a)(1)(C), and Title 28,
United States Code, Section 2461(c), any property, real and or personal,
which constitutes and is derived from proceeds traceable to the offense.
The property to be forfeited shall include but is not limited to, a
money judgment in favor of the United States in an amount equal to the
total amount of proceeds obtained directly or indirectly as a result of

the offense.
10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 3:23-cr-00386-LAB Document 22 Filed 03/28/23 PagelD.98 Page3of3

3. Upon conviction of the offense in violation of Title 18 U.S.C.
§ 1956(h) as set forth in Count 2 of this Information, defendant,
CONSTANTIN BOBI SANDU, aka Bobi Sandu, aka Ionut Mihai, aka Constantin
Sandu, shall forfeit to the United States of America, pursuant to Title
18, United States Code, Section 982(a)(1), any property, real and
personal, involved in the offense and any property traceable to such
property.
4, If any of the property described above, as a result of any
act or omission of the defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a
third party;
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
divided without difficulty, the United States of America shall be
entitled to forfeiture of substitute property pursuant to Title 18,
United States Code, Section 982(b) and Title 28, United States Code,
Section 2461(c).

DATED: 3/16/2023

RANDY S. GROSSMAN
United States Attorney

JESSICA ADELINE SCHULBERG
Assistant U.S. Attorney


File and source

File

22-information-as-to-constantin-bobi-sandu.pdf

Size

599,080 bytes

SHA-256

d9957dec756992a117813a2aa08a802117eff4992717f498e70935e22d0fc335

Our copy

22-information-as-to-constantin-bobi-sandu.pdf

Original

PACER (login required)