Case 6:17-cr-00455-AA Document 1 Filed 12/14/17 Page 1 of 6

FILED 14DEC '1714:51 USDC-ClRE

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

EUGENE DIVISION

UNITED STATES OF AMERICA 6:17-CR- 45'5- AA

v. INDICTMENT

RICHARD MACADANGDANG SALES, 18 U.S.C. §§ 1343 and 1957

Defendant. Forfeiture Allegation(s)

UNDER SEAL

THE GRAND JURY CHARGES:

COUNTS 1 THROUGH 4
(Wire Fraud)
(18 u.s.c. § 1343)

1. Beginning no later than 2011 and continuing through in or about 2013, in the

District of Oregon and elsewhere, defendant RICHARD MACADANGDANG SALES devised

and intended to devise a scheme and artifice to defraud and to obtain monies by means of false

and fraudulent pretenses, representations, and promises, and during such period stated above,

executed and attempted to execute such scheme and artifice and, in so doing, transmitted and

caused to be transmitted in interstate and foreign commerce, by means of wire communications,

certain electronic sounds, signals and writings, such scheme and artifice and wire

communications being more fully and specifically set forth below.

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MANNER AND MEANS AND SCHEME TO DEFRAUD

2. SALES used the following manner and means to carry out the material scheme

and artifice to defraud:

3. In 2011, SALES began soliciting investors to fund his expenses for locating,

possessing, and negotiating certain assets he claimed were worth millions of dollars.

4. Although SALES' description of the details of the investment varied, generally,

the investors were led to believe that SALES possessed the ability to recover hundreds of

millions of dollars worth of U.S. Treasury Notes that were located in East Asia and the Pacific.

5. SALES claimed that, as part of this recovery process, he would take control of a

certain percentage of these funds and use them to build humanitarian housing projects for victims

of natural disasters in third world countries.

6. SALES falsely represented that the investments, structured in the form ofloans,

would provide a quick return on investment, within approximately 60 days, and high returns of

as much as 100%.

7. In addition to benefiting from the payment of interest on these loans, SALES

falsely claimed that the investors, many of whom worked in the construction industry, would

benefit by being the recipients of building contracts for these housing units.

8. SALES utilized investors L.H. and C.R. to solicit other investors on his behalf.

9. SALES falsely secured the investments through a document titled "Warrant" and

signed by SALES. In this document, SALES agreed to underwrite all loans negotiated on his

behalf. The warrants were provided to investors to alleviate their concerns regarding repayment

of their investments.

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10. SALES represented that he was the "Commissaris" of a secret group comprised

of heads of state, world-renowned economists, the Vatican, and others. He claimed the "doctrine

of our syndicate" carried the signatures of "John F. Kennedy, Pope John Paul VI, Golda Meir,

Chang Kai Shek, Lee Kuan Yew, Queen Victoria and many others."

11. SALES claimed that this group financed thousands of projects worldwide. In

addition, SALES falsely claimed that the United Nations "is just a front for what we want to do."

12. SALES represented that this group had given away or granted over one trillion

dollars for "projects" around the world. SALES also falsely stated that he had personally given

away billions of dollars.

13. SALES falsely claimed that he maintained high-level contacts in governments

throughout the world, which allowed him access to the treasury notes and the unique ability to

tum these assets into returns for the investors.

14. At various times during the scheme, SALES falsely represented that he had

possession of "authentic, legal and registered assets" totaling more than $3 billion; that he had

over $26 billion in U.S. Treasury Notes in his possession; and that he had "personally in a vault

in Hong Kong" more than $800 billion in "authenticated assets."

15. Throughout the scheme, SALES requested additional funds from the investors in

order for him to purportedly continue his collection of assets on behalf of the investors.

16. SALES communicated with investors via phone, email, and other internet
. .
messagmg services.

17. Based on SALES' material false statements and representations regarding the

assets he controlled, the assets he could access, his personal connections with world leaders and

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others of notoriety, and his many other representations regarding his own notoriety, individuals

invested their money with SALES.

18. Based on SALES' material false promises and statements, investors gave SALES

more than $900,000.

19. At all times material and relevant herein, L.H., C.R., A.A., A.D., and R.D.,

persons known to the Grand Jury, were residing in Oregon.

WIRE COMMUNICATIONS

20. On or about the dates set forth below in each Count, in the District of Oregon and

elsewhere, SALES, for purposes of attempting to execute and executing the above-described

material scheme and artifice to defraud and for obtaining money and property by means of

materially false and fraudulent pretenses, representations, promises, and omissions of material

facts, knowingly caused the following communications via interstate wire:

COUNT DATE DESCRIPTION OF EXECUTION

1 December 18, 2012 A $15,000 transfer by check from victim L.H.

deposited in Oregon and credited via interstate wire
to an account at Bank of America in Washington.
2 February 26, 2013 A $20,000 transfer via interstate wire from victim
R.D. in Oregon to an account at Bank of America.
3 April 19, 2013 A $20,000 transfer via interstate wire from victims
S.A. and A.A. in Oregon to an account at Bank of
America.
4 July 15, 2013 A $16,000 transfer via interstate wire from victim
A.D. in Oregon to an account at Bank of America.

All in violation of 18 U.S.C. § 1343.

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COUNTS
(Money Laundering)
(18 u.s.c. § 1957)

21. Paragraphs 1 through 20 are incorporated herein.

22. As set forth below, in the District of Oregon and elsewhere, defendant

RICHARD MACADANGDANG SALES knowingly engaged in and attempted to engage in a

monetary transaction, by, through, and to a financial institution, in and affecting interstate

commerce, in criminally derived property that was of a value greater than $10,000 and was

derived from a specified unlawful activity (wire fraud):

COUNT MONETARY TRANSACTION

5 On or about July 15, 2013, SALES caused $14,000 to be transferred from his
Bank of America account to the account of A.M.

In violation of 18 U.S.C. § 1957.

FORFEITURE ALLEGATION

Upon conviction of the offenses alleged in Counts 1 through 5 of this indictment,

RICHARD MACADANGDANG SALES, shall forfeit to the United States, pursuant to Title

18, United States Code, Sections 98l(a)(l)(C), 982(a)(2), and Title 28, United States Code,

Section 2461(c), any property, real or personal, which constitutes or is derived from proceeds

traceable to the violations.

If any of the above-described forfeitable property, as a result of any act or omission of

SALES:

(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;

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(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided without

difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section

853(p) as incorporated by Title 18, United States Code, Section 982(b ), to seek forfeiture of any

other property of SALES up to the value of the forfeitable property described above.

Dated this 14=· day of December 2017.

A TRUE BILL.

Presented by:

BILLY J. WILLIAMS
United States Attorney

~!NW~----
Assistant United States Attorney

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