Robert Swan Mueller

“ Many of the bank accounts purchased by PINEDO over the internet were created using stolen identities of U.S. persons. Although PINEDO was not directly involved in the registration of these accounts using stolen identities, he willfully and intentionally avoided learning about the use of stolen identities.
3. Company 1 required users to submit bank account numbers as a means of verifying a user's identity. To circumvent this requirement, certain users (hereinafter "Users") registered for Company 1's online services with bank account numbers in the names of other people. ”

“ These facts do not constitute all of the facts known to the parties concerning the charged offense; they are being submitted to demonstrate that sufficient facts exist that the defendant committed the offense to which he is pleading guilty. ”

“ PINEDO sold Users bank account numbers over the internet to aid and abet, and in connection with, this scheme to defraud Company 1 by means of internet communications in interstate and foreign commerce. ”