The U.S. Government's Original Indictment Against Sam Bankman-Fried Contained No Factual Allegations

PRELIMINARY STATEMENT

II. BACKGROUND TO ALL MOTIONS

F. The Original Indictment

The Government filed its first indictment against Mr. Bankman-Fried on December 9, 2022, charging him with eight counts: wire fraud and conspiracy to commit wire fraud against FTX’s customers, wire fraud and conspiracy to commit wire fraud against Alameda’s lenders, securities fraud and conspiracy to commit securities fraud against FTX’s investors, one count of money laundering conspiracy, and one count of conspiracy to violate the federal campaign finance laws. The Original Indictment contained virtually no factual allegations and did not identify basic information about the Government’s charging theory, such as the lenders, the loan agreements, or the allegedly false statements underlying the lender fraud counts, or the investors, the stock offerings, or the allegedly false statements underlying the investor counts.