it says there:
On or about August 12, 2006, a cooperating
witness (the “CW”), who at the time was located in Miami, Florida,
used a computer to open an account on Neteller.com (the “Neteller
Account”), and the CW electronically transferred $400 from a bank
account in Miami, Florida, into the Neteller Account. On or about
August 22, 2006, the CW, who at the time was located in Miami,
Florida, used a computer to open a wagering account with an online
gambling business based in Antigua (“Online Gambling Business #1),
by electronically transferring $400 from the Neteller Account to
Online Gambling Business #1. On or about August 24, 2006, the CW,
who at the time was located in Miami, Florida, used a computer to
access Online Gambling Business #1’s website, and the CW then
wagered $250 on a National Football League (“NFL”) football game
and won approximately $200. On or about September 7, 2006, the CW,
who at the time was located in Miami, Florida, used a computer to
access Online Gambling Business #1’s website, and the CW then
wagered $250 on an NFL football game and lost $250.
and more of the same and then:
I have reviewed various business records obtained
from financial institutions that provide information regarding
international monetary transactions conducted by, or on behalf of,
Neteller PLC, including the following:
a. Records of automated clearinghouse (“ACH”)
transactions obtained pursuant to subpoena from an automated
clearinghouse located in the United States demonstrate that
Neteller processes a significant amount of customer transactions
through the automated clearinghouse system, including transactions
from customers in Manhattan. The ACH system permits Neteller to
handle internet-based customer transactions. These records further
demonstrate that Neteller uses a payment service company (the
“Payment Company”) to conduct its customers’ ACH transactions in
the name of the Payment Company. By doing so, Neteller PLC
conceals the nature of these financial transactions. The Payment
Company receives funds in the United States on behalf of Neteller
PLC, and then transfers the funds out of the United States to
accounts controlled by Neteller PLC in Canada.
And later:
I have reviewed various business records of Neteller
PLC that demonstrate that STEPHEN ERIC LAWRENCE, the defendant, had
knowledge that he was participating in criminal activity in the
United States. For example, in the Neteller IPO Prospectus, the
Board of Directors of Neteller PLC, including LAWRENCE,
collectively states that criminal laws exist in the United States
that prohibit persons from promoting certain forms of gambling;
criminal laws exist in the United States that prohibit the
transmission of funds that are known to have been derived from
criminal activity or are intended to promote criminal activity;
that to date most of the criminal prosecutions related to online
gambling in the United States have been limited to cases where
assets or relevant individuals are located in the United States;
that the Neteller Group does not maintain offices or assets in the
United States; and that there can be no assurance that the
government of the United States will not try to prosecute the
Neteller Group under existing or future federal laws