Case 1:17-cr-00011-CCC Document 3-1 Filed 01/19/17 Page 17 of 31
Victims of the Scheme to Defraud
54. Below are examples of victims of the consumer fraud scheme perpetrated via Western
Union’s Money Transfer System. Each of these victims was defrauded through Agents
that had already paid 15 CFRs in 120 days.
a. MV, a 60-year-old resident of the Middle District of Pennsylvania reported that in
February 2006, a Fraudster contacted MV and falsely promised him that if he paid
legal fees up front, he would receive a $1 million prize. On February 2, 2006,
MV visited a Western Union Agent location in the Middle District of
Pennsylvania and sent a $4,500 money transfer to claim his prize. UK Western
Union Agent 2 in London, United Kingdom paid MV’s transfer on February 3,
2006. MV never received the prize he was promised.
b. AI, a resident of the Middle District of Pennsylvania reported in July 2006, a
Fraudster contacted AI and falsely promised her that if she paid money up front
she would receive a sweepstakes prize. On July 8, 2006 and July 14, 2006, AI
visited Western Union Agent locations in the Middle District of Pennsylvania and
sent transactions of $1,500 and $1,750 to claim her prize. On July 10, 2006 and
July 15, 2006, UK Western Union Agent 2 in London, United Kingdom, paid out
AI’s transfers. AI never received the prize she was promised. AI reported the
fraud to Western Union.
c. TD, a resident of the Middle District of Pennsylvania reported in May 2008, a
Fraudster contacted TD and falsely promised him a motorcycle in exchange for an
advance payment. On May 29, 2008, TD visited a Western Union Agent location
in the Middle District of Pennsylvania and sent a $1,300 money transfer in
exchange for the motorcycle. On May 31, 2008, UK Agent Western Union 2 in
London, United Kingdom, paid out TD’s transfer. TD never received the
motorcycle he was promised. TD reported the fraud to Western Union.
d. FS, a resident of the Middle District of Pennsylvania reported in May 2010, a
Fraudster contacted FS and falsely promised to pay him for cashing checks
provided FS paid the Fraudster the value of the checks in advance. On May 19,
2010, FS visited a Western Union Agent location in the Middle District of
Pennsylvania and sent a $2,000 money transfer to receive the checks. UK
Western Union Agent 1 in London, United Kingdom paid FS’s transfer on May
20, 2010. The checks FS received were counterfeit and FS never received the
payment he was promised. FS reported the fraud to federal investigators.
e. PM, a 65-year-old resident of the Middle District of Pennsylvania reported that in
May 2010, a Fraudster contacted PM and falsely promised her that if she paid fees
up front she would receive prize money from a sweepstakes. Between May 1,
2010 and September 15, 2010, PM visited a Western Union Agent location in the
Middle District of Pennsylvania and sent seven Western Union transactions
totaling $9,550 to claim the prize. A Western Union Agent in London, United
Kingdom, paid three of PM’s transfers totaling $3,450. PM never received the
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