Sample IndictmentConcealing a Scheme or Artifice
to Defraud, 18 U.S.C. § 157
(Ponzi and Bust Out schemes often use bankruptcy as a means of
delaying and hindering creditors and investigators. By using bankruptcy to
hide the scheme they will violate this section.)|
- From on or about _______ to on or about _____ , in the
_________ District of ______, JOHN DOE, defendant herein, devised a scheme
or artifice to defraud investors of money by falsely promising that their
investments of money with him would double every six months and that this
return was possible because of his contacts with foreign investors who need
to move money from their country to the United States. In fact, JOHN DOE
had no foreign investors and was engaged in a scheme to use new investors'
money to pay some return to the initial investors, while diverting
substantial portions of the investments to his personal use.
- On or about the __________ day of ____________ , Defendant JOHN DOE
for the purpose of concealing from his investors the fact that he was unable
to pay the promised return and that their money had been diverted to his
personal use, filed a bankruptcy petition under title 11.
All in violation of 18 U.S.C. § 157.
[cited in USAM 9-41.001]