COUNT THREE: Conspiracy to Commit Wire Fraud on Lenders
The Grand Jury further charges:
- From at least in or about June 2022, up to and including in or about November 2022, in the Southern District of New York, and elsewhere, SAMUEL BANKMAN-FRIED, a/k/a “SBF,” the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit wire fraud, in violation of Title 18, United States Code, Sections 1343.
- It was a part and object of the conspiracy that SAMUEL BANKMAN-FRIED, a/k/a “SBF,” the defendant, and others known and unknown, knowingly having devised and intending to devise a scheme and artifice to defraud, and for obtaining money and property by means of false and fraudulent pretenses, representations, and promises, would and did transmit and cause to be transmitted by means of wire, radio, and television communication in interstate and foreign commerce, writings, signs, signals, pictures, and sounds for the purpose of executing such scheme and artifice, in violation of Title 18, United States Code, Section 1343, to wit, BANKMAN-FRIED agreed with others to defraud lenders to Alameda Research, BANKMAN-FRIED’s proprietary crypto hedge fund, by providing false and misleading information to those lenders regarding Alameda Research’s financial condition.
(Title 18, United States Code, Section 1349.)
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SBF knowingly ‘devised a scheme’ to defraud Alameda investors, per Grand Jury Indictment
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