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Superseding Information, United States v. Constantin Bobi Sandu (S.D. Cal., July 11, 2023)

Summary

A superseding Information filed July 11, 2023 as Document 37 in United States v. Constantin Bobi Sandu, aka Bobi Sandu, aka Ionut Mihai, aka Constantin Sandu, Case No. 23CR0386-LAB, in the U.S. District Court for the Southern District of California, dated 7/8/2023. Count 1 charges a money laundering conspiracy under Title 18, United States Code, Sections 1956(a)(2)(A) and (h) from in or about September 2020 to in or about August 2022, to move funds abroad to promote a wire fraud conspiracy. Count 2 charges conspiracy to commit wire fraud under Title 18, U.S.C. § 1349 from in or about July 2020 to in or about August 2022. Count 3 charges laundering of monetary instruments for a transfer of approximately $2,367.15 USD on or about August 10, 2021 to a bank account in Romania, and the Information adds criminal forfeiture allegations.

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Cite this document

“Superseding Information, United States v. Constantin Bobi Sandu (S.D. Cal., July 11, 2023).” Original at ecf.casd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/superseding-information-usa-v-sandu-dkt-37-s-d-cal-a9567f23c2/, SHA-256 fcfb57fc7ed2c408fa6e48ee8a5589e7460db24ff47c3b9ebceaadf2cf77eff9.

Full text

     Case 3:23-cr-00386-LAB   Document 37   Filed 07/11/23   PageID.195   Page 1 of 4



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7                              UNITED STATES DISTRICT COURT
8                             SOUTHERN DISTRICT OF CALIFORNIA
9

10         The United States Attorney charges:
11 UNITED STATES OF AMERICA,                     Case No. 23CR0386-LAB

12                     Plaintiff,                I N F O R M A T I O N
                                                      Superseding
13
            v.
                                                 Title 18, U.S.C. § 1349 -
14                                               Conspiracy to Commit Wire
   CONSTANTIN BOBI SANDU,
                                                 Fraud;
15 aka Bobi Sandu,
   aka Ionut Mihai,
                                                 Title 18 U.S.C. § 1956(a)(2)(A)-
16 aka Constantin Sandu,                         Laundering Monetary Instruments;
17                      Defendant.
                                                 Title 18 U.S.C. §§ 981(a)(1)(C)
18                                               and 982(a)(1), and Title 28,
                                                 U.S.C. § 2461(c)- Criminal
19                                               Forfeiture

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21                                      Count 1

22         Beginning in or about September 2020, and continuing to in or about

23 August 2022, in the Southern District of California, and elsewhere,

24 Defendant CONSTANTIN BOBI SANDU, Aka Bobi Sandu, Aka Ionut Mihai, Aka

25 Constantin Sandu, knowingly conspired and agreed with other persons

26 known and unknown, to commit the following money laundering offense: to
27 transport, transmit and transfer and attempt to transport, transmit and

28 transfer      monetary instruments and funds from a place in the United

     JSCH:San Diego
     6/28/23
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     Case 3:23-cr-00386-LAB     Document 37     Filed 07/11/23   PageID.196     Page 2 of 4




1 States to and through a place outside the United States with the intent

2 to promote the carrying on of specified unlawful activity, that is

3 violations of Conspiracy to Commit Wire Fraud in violation of 18 U.S.C.

4 § 1349; all in violation of Title 18, United States Code, Sections

5 1956(a)(2)(A) and (h).

6                                            Count 2

7          Beginning in or about July 2020, and continuing to in or about

8 August 2022, in the Southern District of California, and elsewhere,

9 Defendant CONSTANTIN BOBI SANDU, aka Bobi Sandu, Aka Ionut Mihai, Aka

10 Constantin Sandu, knowingly and intentionally conspired and agreed with

11 other persons known and unknown, to commit wire fraud in violation of

12 Title 18, United States Code, Section 1343; all in violation of United

13 States Code Section 1349.

14                                              Count 3

15         On or about August 10, 2021, defendant CONSTANTIN BOBI SANDU,                      aka

16 Bobi     Sandu,       Aka   Ionut   Mihai,    Aka      Constantin   Sandu,     transported,

17 transmitted, and transferred a monetary instrument and funds from a

18 place in the United States to a place outside the United States—

19 approximately $2,367.15 USD from a bank account in the United States to

20 a bank account controlled, managed, supervised, directed, and owned by

21 I.T. in Romania—with the intent to promote the carrying on of specified

22 unlawful activity, to wit, Wire Fraud in violation of Title 18, United

23 States Code, Section 1343; all in violation of Title 18, United States

24 Code, Section 1956(a)(2)(A).

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                               Criminal Forfeiture Allegations
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           1.     The allegations contained in Counts 1-3 are re-alleged and
27 incorporated by reference for the purpose of alleging forfeiture to the

28 United       States    pursuant     to   Title   18,    United   States    Code,    Sections
                                                    2

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     Case 3:23-cr-00386-LAB   Document 37   Filed 07/11/23   PageID.197   Page 3 of 4



     981(a)(1)(C) and 982(a)(1), and Title 28, United States Code, Section
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     2461(c).
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           2.    Upon conviction of the offenses set forth in Counts 1 or 3 of
 3 this Superseding Information, defendant, CONSTANTIN BOBI SANDU, aka Bobi

 4 Sandu, aka Ionut Mihai, aka Constantin Sandu, shall forfeit to the United

 5 States of America all their rights, title, and interest, pursuant to
   Title 18, United States Code, Section 982(a)(1), in any property, real
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   and personal, involved in the offense and any property traceable to such
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   property.
 8      3.   Upon conviction of the offense set forth in Count 2 of this
 9 Superseding Information, defendant, CONSTANTIN BOBI SANDU, aka Bobi

10 Sandu, aka Ionut Mihai, aka Constantin Sandu, shall forfeit to the United

11 States of America all their rights, title, and interest, pursuant to
   Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United
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   States Code, Section 2461(c), in any property, real and personal, which
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   constitutes and is derived from proceeds traceable to the offense.
14      4.   If any of the property described above, as a result of any
15 act or omission of the defendant:

16               a. cannot be located upon the exercise of due diligence;
                 b. has been transferred or sold to, or deposited with, a
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     third party;
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                 c. has been placed beyond the jurisdiction of the court;
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                 d. has been substantially diminished in value; or
20               e. has been commingled with other property which cannot be
21 divided without difficulty, the United States of America shall be

22 entitled to forfeiture of substitute property pursuant to Title 21,
   United States Code, Section 853(p), Title 18, United States Code, Section
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   982(b) and Title 28, United States Code, Section 2461(c).
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   All pursuant to Title 21, United States Code, Sections 981(a)(1)(C),
25 982(a)(1), and 982(b), and Title 28, United States Code, Section 2461(c).

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     Case 3:23-cr-00386-LAB   Document 37   Filed 07/11/23   PageID.198   Page 4 of 4



           DATED: 7/8/2023
                  _____________.
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                                                     RANDY S. GROSSMAN
 2                                                   United States Attorney
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 4                                                   JESSICA ADELINE SCHULBERG
                                                     Assistant U.S. Attorney
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