Sterling is being charged with FRAUD

I. Introduction

This Complaint seeks forfeiture of the
below-listed properties to the United
States as proceeds of specified unlawful
activities and properties involved in
money laundering offenses of Sterling
Currency Group, LLC (“Sterling”); Sterling
Online Processing Services, LLC (Sterlin
g Online); GID Partners, LLC (GID); Alex
Capital Holdings LLC (Alex); James Sh
aw (J.Shaw); Carole Laurette Shaw
(C.Shaw); Tyson Rhame (Rhame); Frank Bell (B
ell), and other entities controlled by
these same businesses and individuals that have used the facilities of interstate

commerce in a scheme to defraud investor

s in the Iraqi dinar by publishing and

disseminating false information about th

e viability of that currency as an


Based on the evidence described below,
the Defendant Properties are subject
to forfeiture to the United States pursuant
to 18 U.S.C. § 981(a)(1)(C) as proceeds of
specified unlawful activity
traceable directly and indire
ctly to violations of 18
U.S.C. §§ 1341, 1343,
1349, 1956, and 1957.
Additionally, the Defendant Properties ar
e subject to forfeiture to the United
States pursuant to 18 U.S.C. § 981(a
)(1)(A) as property involved in money
laundering offenses in violation
of 18 U.S.C. §§ 1956 and 1957.
This Court has jurisdiction over this
action and the claims raised herein by
virtue of 28 U.S.C.
§§ 1345 and 1355(a).
Venue is proper in the Northern Distri
ct of Georgia as
to the Valley Road
Property, the Dresden Property, the
Paces Place Property, the Brookhaven
Property, the Heather Drive Property, the
Black Mercedes, the Silver Mercedes, and

Knowledge of the Scam
Sterling’s success is at leas
t partially attributable to its use of the facilities of
interstate commerce, including wire commun
ications, both directly and indirectly,
to disseminate false and misleading
information about the possibility of a
revaluation of the dinar and to steer cu
stomers toward choosing Sterling over its