Wire fraud inditement
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2024R00057
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA
v.
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko”
a/k/a “FlankerWWH,” and
a/k/a “Flanker”
:
:
:
:
:
:
:
:
Hon.
Criminal No. 24-
18 U.S.C. § 1030(a)(2)(C)
18 U.S.C. § 1343
18 U.S.C. § 2
INDICTMENT
The Grand Jury in and for the District of New Jersey, sitting at Newark
charges:
COUNT ONE
(Wire Fraud)
1. At all times relevant to this Indictment:
a. Defendant EVGENIY DOROSHENKO, a/k/a Eugene
Doroshenko,” a/k/a “FlankerWWH,” and a/k/a “Flanker” (“DOROSHENKO”) was a
citizen and resident of Russia.
b. An “access broker” was an individual who acquired and sold
unlawful access to victim computer systems. Typically, access brokers sold this
access to individuals committing various types of computer-related crimes, such as
business email compromises, unlawful exfiltration of data, and ransomware attacks.
c. “Cybercrime Forums” were online forums where, either overtly
through public messages or covertly through private messages, cybercriminals
promoted and facilitated a wide variety of criminal activities including, among other
activities, computer hacking and trafficking in stolen data.
2
d. Cybercrime Forum-1 was a Russian language Cybercrime Forum
accessible through the dark web, meaning it was accessible only through The Onion
Router (“Tor”) network, which anonymized the Internet Protocol (“IP”) addresses of
its underlying servers.
e. Victim-1 was a company with headquarters in Bergen County,
New Jersey.
Overview of the Wire Fraud Scheme
2. From at least as early as February 25, 2019 through on or about the date
of this Indictment, in the District of New Jersey and elsewhere, the defendant,
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko,”
a/k/a “FlankerWWH,”
a/k/a “Flanker
did knowingly and intentionally devise and intend to devise a scheme and artifice to
defraud victims, including Victim-1, and to obtain money and property by means of
materially false and fraudulent pretenses, representations, and promises, as set forth
more fully below.
Object of the Scheme
3. The object of the scheme was for DOROSHENKO to profit unlawfully by
obtaining unauthorized access to victim computer networks and then acting as an
access broker by selling the unauthorized access to others over Cybercrime Forum-1.
Manner and Means of the Scheme
4. It was part of the scheme that:
3
a. DOROSHENKO unlawfully obtained access credentials to victim
computer networks, including Victim-1’s computer network.
b. DOROSHENKO used the unlawfully obtained access credentials
to gain unauthorized access to victim computer networks, including Victim-1’s
computer network.
c. DOROSHENKO then sold and offered to sell access to victim
computer networks, including Victim-1’s computer network, over Cybercrime Forum1.
Execution of the Scheme
5. On or about January 11, 2024, in Bergen County, in the District of New
Jersey, and elsewhere, for the purpose of executing and attempting to execute this
scheme and artifice to defraud, the defendant,
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko,”
a/k/a “FlankerWWH,” and
a/k/a “Flanker,”
did knowingly transmit and cause to be transmitted by means of wire
communications in interstate and foreign commerce certain writings, signs, signals,
pictures, and sounds, namely, DOROSHENKO, while located in Russia, remotely
connected to the computer network of Victim-1 in the District of New Jersey.
In violation of Title 18, United States Code, Section 1343 and Section 2.
4
COUNT TWO
(Computer Fraud)
1. The allegations in paragraphs 1, 3, and 4 of Count One of this
Indictment are re-alleged here.
2. From on or about January 11, 2024 through on or about January 17,
2024, in Bergen County, in the District of New Jersey, and elsewhere, the defendant,
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko,”
a/k/a “FlankerWWH,” and
a/k/a “Flanker,”
intentionally accessed and exceeded authorized access to a protected computer, that
is the computer network of Victim-1, used in and affecting interstate and foreign
commerce, and communication, and thereby obtained information from a protected
computer, for the purpose of commercial advantage and private financial gain, in
furtherance of a criminal and tortious act in violation of the laws of the United States,
including wire fraud, in violation of Title 18, United States Code, Section 1343, and
the value of the information exceeded $5,000.
In violation of Title 18, United States Code, Sections 1030(a)(2)(C) and
(c)(2)(B)(i-iii) and Section 2.
5
FORFEITURE ALLEGATION
1. Upon conviction of either of the offenses charged in this Indictment, the
defendant,
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko,”
a/k/a “FlankerWWH,” and
a/k/a “Flanker,”
shall forfeit to the United States:
a. pursuant to Title 18, United States Code, Sections 982(a)(2)(B)
and 1030(i), any property, real or personal, constituting, or derived from, proceeds
obtained directly or indirectly as a result of the offenses charged in this Indictment;
and
b. pursuant to Title 18, United States Code, Section 1030(i), all
right, title, and interest of the defendant in any personal property that was used or
intended to be used to commit or to facilitate the commission of the offenses charged
in this Indictment.
SUBSTITUTE ASSETS PROVISION
2. If any of the above-described forfeitable property, as a result of any act
or omission of the Defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
6
e. has been commingled with other property which cannot be
divided without difficulty,
the United States shall be entitled, pursuant to Title 21, United States Code, Section
853(p) (as incorporated by Title 28, United States Code, Section 2461(c), Title 18,
United States Code, Section 1030(i), and Title 18, United States Code, Section 982(b)),
to forfeiture of any other property of the defendant up to the value of the abovedescribed forfeitable property.
A TRUE BILL
_________________________________
FOREPERSON
____________________________
PHILIP R. SELLINGER
United States Attorney r ...:::P
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2024R00057
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA
v.
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko”
a/k/a “FlankerWWH,” and
a/k/a “Flanker”
:
:
:
:
:
:
:
:
Hon.
Criminal No. 24-
18 U.S.C. § 1030(a)(2)(C)
18 U.S.C. § 1343
18 U.S.C. § 2
INDICTMENT
The Grand Jury in and for the District of New Jersey, sitting at Newark
charges:
COUNT ONE
(Wire Fraud)
1. At all times relevant to this Indictment:
a. Defendant EVGENIY DOROSHENKO, a/k/a Eugene
Doroshenko,” a/k/a “FlankerWWH,” and a/k/a “Flanker” (“DOROSHENKO”) was a
citizen and resident of Russia.
b. An “access broker” was an individual who acquired and sold
unlawful access to victim computer systems. Typically, access brokers sold this
access to individuals committing various types of computer-related crimes, such as
business email compromises, unlawful exfiltration of data, and ransomware attacks.
c. “Cybercrime Forums” were online forums where, either overtly
through public messages or covertly through private messages, cybercriminals
promoted and facilitated a wide variety of criminal activities including, among other
activities, computer hacking and trafficking in stolen data.
2
d. Cybercrime Forum-1 was a Russian language Cybercrime Forum
accessible through the dark web, meaning it was accessible only through The Onion
Router (“Tor”) network, which anonymized the Internet Protocol (“IP”) addresses of
its underlying servers.
e. Victim-1 was a company with headquarters in Bergen County,
New Jersey.
Overview of the Wire Fraud Scheme
2. From at least as early as February 25, 2019 through on or about the date
of this Indictment, in the District of New Jersey and elsewhere, the defendant,
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko,”
a/k/a “FlankerWWH,”
a/k/a “Flanker
did knowingly and intentionally devise and intend to devise a scheme and artifice to
defraud victims, including Victim-1, and to obtain money and property by means of
materially false and fraudulent pretenses, representations, and promises, as set forth
more fully below.
Object of the Scheme
3. The object of the scheme was for DOROSHENKO to profit unlawfully by
obtaining unauthorized access to victim computer networks and then acting as an
access broker by selling the unauthorized access to others over Cybercrime Forum-1.
Manner and Means of the Scheme
4. It was part of the scheme that:
3
a. DOROSHENKO unlawfully obtained access credentials to victim
computer networks, including Victim-1’s computer network.
b. DOROSHENKO used the unlawfully obtained access credentials
to gain unauthorized access to victim computer networks, including Victim-1’s
computer network.
c. DOROSHENKO then sold and offered to sell access to victim
computer networks, including Victim-1’s computer network, over Cybercrime Forum1.
Execution of the Scheme
5. On or about January 11, 2024, in Bergen County, in the District of New
Jersey, and elsewhere, for the purpose of executing and attempting to execute this
scheme and artifice to defraud, the defendant,
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko,”
a/k/a “FlankerWWH,” and
a/k/a “Flanker,”
did knowingly transmit and cause to be transmitted by means of wire
communications in interstate and foreign commerce certain writings, signs, signals,
pictures, and sounds, namely, DOROSHENKO, while located in Russia, remotely
connected to the computer network of Victim-1 in the District of New Jersey.
In violation of Title 18, United States Code, Section 1343 and Section 2.
4
COUNT TWO
(Computer Fraud)
1. The allegations in paragraphs 1, 3, and 4 of Count One of this
Indictment are re-alleged here.
2. From on or about January 11, 2024 through on or about January 17,
2024, in Bergen County, in the District of New Jersey, and elsewhere, the defendant,
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko,”
a/k/a “FlankerWWH,” and
a/k/a “Flanker,”
intentionally accessed and exceeded authorized access to a protected computer, that
is the computer network of Victim-1, used in and affecting interstate and foreign
commerce, and communication, and thereby obtained information from a protected
computer, for the purpose of commercial advantage and private financial gain, in
furtherance of a criminal and tortious act in violation of the laws of the United States,
including wire fraud, in violation of Title 18, United States Code, Section 1343, and
the value of the information exceeded $5,000.
In violation of Title 18, United States Code, Sections 1030(a)(2)(C) and
(c)(2)(B)(i-iii) and Section 2.
5
FORFEITURE ALLEGATION
1. Upon conviction of either of the offenses charged in this Indictment, the
defendant,
EVGENIY DOROSHENKO,
a/k/a “Eugene Doroshenko,”
a/k/a “FlankerWWH,” and
a/k/a “Flanker,”
shall forfeit to the United States:
a. pursuant to Title 18, United States Code, Sections 982(a)(2)(B)
and 1030(i), any property, real or personal, constituting, or derived from, proceeds
obtained directly or indirectly as a result of the offenses charged in this Indictment;
and
b. pursuant to Title 18, United States Code, Section 1030(i), all
right, title, and interest of the defendant in any personal property that was used or
intended to be used to commit or to facilitate the commission of the offenses charged
in this Indictment.
SUBSTITUTE ASSETS PROVISION
2. If any of the above-described forfeitable property, as a result of any act
or omission of the Defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
6
e. has been commingled with other property which cannot be
divided without difficulty,
the United States shall be entitled, pursuant to Title 21, United States Code, Section
853(p) (as incorporated by Title 28, United States Code, Section 2461(c), Title 18,
United States Code, Section 1030(i), and Title 18, United States Code, Section 982(b)),
to forfeiture of any other property of the defendant up to the value of the abovedescribed forfeitable property.
A TRUE BILL
_________________________________
FOREPERSON
____________________________
PHILIP R. SELLINGER
United States Attorney r ...:::P
