JUDGE Yeti PREET BHARAR 51 © OC,F).7 0 United StatesA Attorney for the : Southern District of New York By: JASON H. COWLEY DANIEL W. LEVY DAVID B. MASSEY Assistant United States One St. Andrew's Plaza New York, New York 10007 Attorneys UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, Plaintiff, x ALL FUNDS ACCOUNT NO. HELD IN THE NAME OF WEGELIN & CO., : Defendants in rem. x a 12 Civ. • PM GgtH1Y N Y CASHIERS • • VERIFIED COMPLAINT Plaintiff United States of America, by its attorney, PREET BHARARA, United States Attorney for the Southern District of New York, for its Verified Complaint alleges, upon information and belief, as follows: I. NATURE OF THE ACTION 1. This an action by the United States of America seeking forfeiture of all funds, approximately $16.2 million, on deposit at UBS AG, Account No. held in the name of Wegelin & Co. (the "Defendant Funds"). The Defendant Funds are subject to forfeiture pursuant to 18 U.S.C. 981(a) (1)(A), as property involved in transactions in violation of 18 U.S.C. § 1956. EFTA01125419