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739 KB

Extraction Summary

6
People
4
Organizations
2
Locations
6
Events
1
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 739 KB
Summary

This legal document, filed on July 13, 2020, argues that a defendant is a flight risk due to significant undisclosed financial assets. It details her access to millions of dollars in foreign bank accounts in Switzerland and England, including a trust account with over $4 million, and highlights several large transactions. The document also notes her recent arrest at a New Hampshire property purchased for over $1 million in cash, suggesting she has not been forthcoming about her wealth and has the means to flee.

People (6)

Name Role Context
the defendant defendant
The central figure of the document, whose financial assets and flight risk are being discussed.
co-signers proposed co-signers
Individuals proposed to purchase the defendant's freedom for $5 million, whose wealth and reliability are questioned.
Trustees of the trust account Trustee
Individuals who manage the defendant's trust account, noted to include a relative and a close associate.
a relative Trustee
Mentioned as one of the Trustees of the defendant's trust account.
a close associate Trustee
Mentioned as one of the Trustees of the defendant's trust account.
a wealthy patron patron
A hypothetical person who may have purchased a New Hampshire property on the defendant's behalf.

Organizations (4)

Name Type Context
the Government government agency
Mentioned in the context of its ability to collect from the defendant's proposed co-signers.
Swiss Bank company
A Swiss bank where the defendant holds multiple accounts and a trust account.
English Bank company
A bank headquartered in England where the defendant has multiple accounts with values over $2 million.
United States Treasury Department government agency
The agency with which Form 114 (“FBAR”) submissions were filed on behalf of the defendant.

Timeline (6 events)

2018-2019
Form 114 ('FBAR') submissions were filed on behalf of the defendant with the US Treasury, listing accounts at the English Bank totaling over $2 million.
2019-03
The defendant transferred approximately $500,000 from a Swiss Bank account to her Trust Account.
2019-06
A transfer of more than $750,000 occurred between the defendant's Swiss Bank accounts.
2019-12
A property was purchased for more than $1 million in cash.
New Hampshire
2020-06
The defendant's Trust Account had a balance of more than $4 million.
2020-07
The defendant was arrested.
New Hampshire

Locations (2)

Location Context
The location where the "English Bank" is headquartered.
The location of a property purchased for over $1 million in cash, where the defendant was arrested.

Relationships (1)

the defendant personal, professional Trustees of the trust account
The Trustees of the defendant's trust account include 'both a relative and a close associate of the defendant.'

Full Extracted Text

Complete text extracted from the document (2,192 characters)

Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 12 of 19
of those individuals, including where they are based or whether the Government would be able to collect from them. Nor does she provide information sufficient to know whether her proposed co-signers are so wealthy that they would be willing to purchase the defendant’s freedom for $5 million, an entirely too modest sum for a person of the defendant’s means. In any event, as further described below, the defendant appears to have the financial resources to make her co-signers whole if she were to flee.
The defendant’s failure to pledge any liquid assets, or to provide detailed financial information about herself or her proposed co-signers, is particularly jarring because she appears to have access to millions of dollars, principally in foreign accounts. In recent years, the defendant has been associated with multiple accounts with a Swiss bank (the “Swiss Bank”) and multiple accounts with at least one bank headquartered in England (the “English Bank”). In 2018 and 2019, Form 114 (“FBAR”) submissions on behalf of the defendant filed with the United States Treasury Department list accounts at the English Bank with maximum values totaling well over $2 million. In connection with the Swiss Bank, the defendant appears to be the grantor of a trust account (the “Trust Account”) with a balance in June 2020 of more than $4 million. Among other transactions, the defendant appears to have transferred approximately $500,000 in March 2019 from one Swiss Bank account in her name to the Trust Account, and records further reflect a transfer between those same accounts in June 2019 of more than $750,000. The Trustees of the trust account, each of whom may act independently according to relevant Trust Account documents, appear to include both a relative and a close associate of the defendant. Additionally, the defendant was arrested last week at a property in New Hampshire that was purchased for more than $1 million in cash in December 2019. It is unknown whether the defendant purchased the property in cash, or whether she has a wealthy patron who did so on her behalf, but either scenario
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DOJ-OGR-00001622

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