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AO 9L (Rev. 1U11) Criminal Complaint AUSA Shoba Pill (312) 886-7631

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DMISION

UNITED STATES OF AMERICA

v. 8ffi'ril"'Y'"f1 3CR 611

Jr crrAoQrrN
MAGISTRATE JUDGE MASON
CRIMINAL COMPI,AIIVT

I, the complainant in this case, state that the following is true to the best of my knowledge
and belief.
From on or about August 28,2013 to on or about September 21,2018, in the Northern
District of Illinois, Eastern Division, and elsewhere, JI CHAOQUN, the defendant violated:
Code Section Offense Description

Title 18, United States Code, Section 951(a) did knowingly act in the United States as an
agent of a foreign government, specifically the

FILED People's Republic of China, without prior

notification
required by law
.to the Attorney General, as

sEP 21 2olo 16

c'IH8Ut'rEf*[YI8U*'

This criminal complaint is based upon these facts:

X sheet.
Continued on the attached
4 ---:?
/
ANDREWK.MCKAY
-t -t
O
Special Agent, Federal Bureau of Investigation

Sworn to before me and signed in my presence.

Date: September 21. 2018

Jufr,ge's signaturb

City and state: Chicago. Illinois MICHAEL T. MASON. U.S. Maeistrate Judee
Printed nanle and Title
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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

Ar.FIDAVIT

I, ANDREW K. MCKAY, being duly sworn, state as follows:

1. I am a Special Agent with the Federal Bureau of Investigation. I have

been so employed since approximately August 2014.

2. As part of my duties as an FBI Special Agent, I investigate criminal

violations relating to espionage offenses, including the gathering or delivery of

defense information to aid a foreign government or agent, in violation of Title 18,

United States Code, Section 794(a), and individuals who act as a foreign agent

without notice to the Attorney General, in violation of Title 18, United States Code,

Section 951(a).

3. This affrdavit is submitted in support of a criminal complaint alleging

that JI CHAOQUN violated Title 18, United States Code, Section 951. The
statements in this affidavit are based on my personal knowledge, and information I

have received from other law enforcement personnel and persons with knowledge of

relevant facts. Because this affidavit is being submitted for the limited purpose of

establishing probable cause in support of a criminal complaint charging JI with

acting as an agent of a foreign government without notice to the Attorney General, I

have not included each and every fact known to me concerning this investigation. I
have set forth only the facts that I believe are necessary to establish probable cause

to believe that the defendant committed the offense alleged in the complaint.
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Bachground

4. Title 18 of the United States Code, section 951 (Agents of Foreign

Governments), makes it a criminal offense for any person, other than a diplomatic or

consular official or attach6, to act in the United States as an agent of a foreign

government without prior notification to the Attorney General, as required by law.

For purposes of this law, the term "agent of a foreign government" includes an

individual who agrees to operate within the United States subject to the direction or

control of a foreign government or official.

People's Republic of China Ministry of State Securit5t

5. Based upon my training and experience, and information obtained from

publicly available sources, the Ministry of State Security ("MSS") for the People's

Republic of China handles civilian intelligence collection and is responsible for

counter-intelligence and foreign intelligence, as well as political security. The MSS

consists of its primary central office, provincial departments, and a number of local

and municipal bureaus. For example, the Jiangsu Province Ministry of State Security

("JSSD") is a provincial department of the MSS. These state and local bureaus report

to both their national ministries and state and local governments and party
committees. The MSS has maintained both a clandestine and overt human source

collection capability through a network of defense attach6s, academics, and spies

operating in and out of China. The MSS's purview and intelligence collection

capability has evolved over time, incorporating new missions as technolory allows.

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6. Based upon my training and experience, and information obtained from

publicly available sources, I am aware that Chinese intelligence services conduct

extensive overt, covert, and clandestine intelligence collection operations against U.S.

national security entities, including private U.S. defense companies, through a

network of agents within and outside of China.l

Southern District of Ohio Inuestigation

7. On or about October 16, 20L7, a search warrant was executed on an

email account (the "Email Account") in connection with an investigation in the

Southern District of Ohio. Emails obtained pursuant to the search warrant showed

the user of the account communicating, coordinating and directing an individual in

the United States ("Individual A") to provide technical information from a U.S.-based

Company (the "Company") without authorization, and providing the information as

a benefit to the Chinese government. Individual A was employed at the Company as

an engineer beginning in or around 2007 through in or around late 20L7.

8. According to the Company, and publicly available information about the

Company, the Company is among the world's top aircraft engine suppliers for both

commercial and military aircraft and undertakes a significant amount of aviation

research for U.S. military aircraft. The Company is a cleared defense contractor and

1Based upon my training and experience, and information obtained from publicly available
sources, I am also aware that Chinese intelligence services typically recruit and employ
agents to collect a wide range of information, including U.S. national security secrets.
Chinese intelligence typically focus their efforts on recruiting ethnic Chinese, primarily
because of cultural and language affinity.
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maintains a U.S. Department of Defense security clearance; however, Individual A

did not have a security clearance while employed at the Company.

9. The search warrant returns from the Email Account obtained in

connection with the ongoing investigation in the Southern District of Ohio revealed

that the user of the Email Account established an iCloud account. In fact, the
Apple ID was the same as the individual's email address.

10. On or about December 8,20L7 , a search warrant issued in the Southern

District of Ohio was executed on the Apple iCloud account related to the same
Apple ID. The contents of the iCloud account included a "Cadre Approval/Removal

Appointment Application Form" for an individual known to law enforcement

("Intelligence Officer A"). This form identified Intelligence Officer A as currently

holding the position of a Deputy Division Director of the JSSD and having held

positions with the MSS since June 2003.

11. On or about November t, 2017, a search warrant was executed at the

residence of Individual A in the Southern District of Ohio. During that search, agents

seized a business card for an individual purportedly employed by an Association for

Science and Technolog;r, located in China. The search warrant return for the iCloud

account contained a text message conversation from December 201"3 in which

Intelligence Officer A wrote in sum and substance, "the customer does not know our

identity. I approached him with the identity of the Deputy Secretary-General

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employed by an Association for Science and Technology."z Based on this message, my

training and experience, as well as conversations with other law enforcement agents

familiar with the investigation in the Southern District of Ohio, I believe that

Intelligence Officer A uses aliases and false claims of emplo5rment when Intelligence

Officer A does not want to disclose an affiliation to the JSSD.

JI CHAOQUN and Intelligence Officer A

L2. According to immigration records, JI CIIAOQUN was born in China and

arrived in the U.S. from Beijing, China on or about August 28,20t3, on an F1 Visa,

for the purpose of studying in the U.S. He received his Master's Degree in Electrical

Engineering at the Illinois Institute of Technology in Chicago in December 2015. In

his FL Visa Application, JI listed his primary phone number as "152)OOOOQ(87" (the

"JI Phone").3

13. Certain text messages from the SMS database from the Apple iCloud

account referenced above suggest that JI was introduced to Intelligence Officer A by

2Certain email and text message communications have been quoted or summarized in this
Affrdavit (the "communications"). The communications are based upon draft-not final-
English translations of Chinese communications completed by interpreters employed by the
FBI. The summaries do not include all statements or topics covered during the course of the
communications.
At various points in the Affidavit I have included my interpretation of words and phrases
used in the communications. My interpretations are based on the contents and context of the
communications, events occurring before and after the communications, my knowledge of the
investigation as a whole, my experience and training, and the experience and training of
other law enforcement agents in this investigation.
3 The complete phone number is redacted because this will be a public filing.

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Intelligence Officer B.a On or about November 29,2013, Intelligence Officer B asked

Intelligence Officer A "Can Little JI use hisftrer real name to frll out forms?" On or

about December 18, 2013, Intelligence Officer B provided the following information

to Intelligence Officer A, "[the JI Phone], JI Chaoqun" and informed Intelligence

Officer A that JI would be on High Speed Rail G203 arriving at Nanjing South Station

at 22:37 .Intelligence Officer A replied to Intelligence Officer B, "Got it. Tell him that

I'm a professor at Nanjing University of Aeronautics and Astronautics."

14. The Apple iCloud SMS database included approximately 36 messages

between Intelligence Officer A and JI, from on or about December 19,2013 to July 9,

20L5.

15. According to his travel records, JI traveled to and from China on three

occasions since his arrival in the U.S. JI traveled to Beijing on or about December 9,

2013, and returned to Chicago on or about January L5,20t4. JI again traveled to

Beijing on or about May 19, z}ir4.,and returned. to Chicago on or about July 6, 20L4.

JI's last trip to China was when he traveled to Beijing on or about December 22,20L4,

and returned to Chicago on or about February,3,20L5.

a The search warrant return for the iCloud account included an entry for Intelligence
Officer B in Intelligence Offrcer A's contact list. The iCloud account also included a database
of SMS text messages. Intelligence Offrcer A's messages with Intelligence Officer B, from the
SMS database for Intelligence Offrcer A s Apple iCloud Account, show that in or around
January through April 20L4, Intelligence Officer B referred to Intelligence Officer A as
"Section Chief' and that Intelligence Officer B provided passwords to Intelligence Officer A.
Intelligence Offrcer B is therefore believed to be a colleague of Intelligence Officer A's in the
JSSD.

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16. According to the Apple iCloud records, on or about December 18, 2013,

JI sent the following message to Intelligence Officer A, stating, "Hi Big Brother, I'm

JI Chaoqun. I'm taking the G203 [train] and will arrive at Nanjing South Station at
22:37." JI and Intelligence Officer A then exchanged several more messages in which

Intelligence Officer A appeared to arrange to meet JI for the first time.

L7 . According to text messages from the SMS Database, on or about January

3, 20t4,Intelligence Officer A asked JI if he could meet the following week. On or

about January l0 , 20L4, JI informed Intelligence Officer A that he was on the subway.

Intelligence Offrcer A then instructed JI where to get offthe subway. Approximately

five hours after this conversation, Intelligence Officer A informed his wife via text

message that he had a suite in a hotel and asked her if she would like to stay. Based

upon these communications and my training and experience, Intelligence Officer A

and JI's second meeting likely occurred in a hotel room. Based upon my training and

experience, conducting meetings in hotel rooms is an indication of intelligence officer

tradecraft because meetings in hotel rooms provide a discreet, private place for the

intelligence officer to recruit or debrief his/her intelligence asset.

18. According to text messages from the SMS Database, on or about January

11,20L4, JI asked Intelligence Officer A to order him a train ticket leaving Nanjing

traveling to Beijing for the following day. Intelligence Officer A instructed JI to send

the train ticket back to Intelligence Officer A when JI returned home. On or about

January L2, 2014, Intelligence Officer A instructed JI to send the tickets to

Intelligence Officer A at an address in Nanjing City, China. Based upon my training

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and experience, Chinese intelligence agencies ofben require intelligence officers to

produce itemized receipts for expenditures related to intelligence assets.

19. Open source research on the Nanjing City address revealed multiple

images identifring the address as the location for the Jiangsu State Security

Department.

20. Additional text messages obtained from Intelligence OfficerA's Apple

iCloud SMS database revealed that on or about June LL,20t4,Intelligence Officer A

and JI coordinated a third meeting in China.

21. Based upon my training and experience, MSS officers often use aliases

or alternate identities when initially meeting potential intelligence assets.

Intelligence Officer A employed this tradecraft by initially using an alias with

Individual A and assuming the identity of a professor with JI. While JI was initially

told that Intelligence Officer A was a professor, it appears that JI learned of

Intelligence Officer A's affiliation with the JSSD because Intelligence Officer A told

JI to send items to the JSSD address, which is listed on public Chinese-language

websites. As explained below, JI later acknowledged in a meeting with an undercover

agent that he believed Intelligence Officer A was part of a "confidential unit" with

Intelligence Oflicer B, and that Intelligence Officer B told him stories about
espionage.

22. On or about March 29,2018, Magistrate Judge Daniel G. Martin issued

a search warrant for the email account pricebid)OO(@gmail.com ("Subject

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Account 1").5 According to the search warrant return, on or about August 30,20L5,

an email was sent from JI, using Subject Account 1, to an email address hosted by

"qq.com," stating, "eight sets of the midterm test questions for the last three years,"

which email was forwarded from Subject Account 1 to Intelligence Officer A.0 The

subject line for the email was "Midterm test questions." Eight separate pdf documents

were attached to the email. The eight separate pdf documents are background reports

on eight U.S.-based individuals generated by U.S.-based companies Intelius, Inc.,

Instant Checkmate, and Spokeo.z

23. According to JI's Discover credit card statements obtained via subpoena,

on or about August 30, 2015, JI's credit card authorized charges in the total amount

of $34.85 from Spokeo. On the same date, JI's credit card authorized charges totaling

$277.35 from Intelius, Inc. According to the JP Morgan Chase records for JI's debit

card obtained via subpoena, JI made multiple purchases totaling $S+.SZ on or about

August 30, 2015; and one purchase totaling $19.95 on or about September 18, 2015,

5 The complete email account is redacted because this will be a public frling.
6According to its website, QQ is an email and instant messaging service developed and
maintained by China-based company Tencent Holding, Ltd.
7 According to their websites, Intelius, Instant Checkmate, and Spokeo are each U.S.-based
companies that offer, among other services, online services for consumers to purchase
background reports about any individual. According to a representative from Intelius, and
its Terms and Conditions, Intelius's services are intended only for U.S.-based consumers, and
it utilizes a tool that restricts access to the Intelius website from China, among other locatiosn
outside the U.S. According to a representative from Instant Checkmate, and its Terms of Use,
purchases from outside the U.S. are strictly prohibited. According to a representative from
Spokeo, and its Terms and Conditions, Spokeo's services are intended only for U.S.-based
consumers, and Spokeo only accepts payment from U.S.-based credit cards with valid U.S.
billing zip codes.

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from Instant Checkmate. According to Spokeo records obtained via subpoena, Subject

Account l- was the email account associated with JI's Spokeo account.

24. According to the IP records associated with JI's account registrations

with the background check companies obtained via subpoena, JI registered his

accounts at Spokeo, Instant Checkmate and Intelius on August 30, 2015, from

IP address 73.51.23.94, which, according to Comcast, is a US-based Comcast IP.

25. In addition, JI's financial and travel records also indicate JI was in the

United States in August and September z}ll,when he purchased and sent the above-

referenced background check reports. According to JI's Discover and JP Morgan

records, his accounts are maintained in the U.S. According to the JP Morgan Chase

records, JI made a debit card purchase at Chicago Ventra on or about August 25,

2015, five days prior to his August 30, 2015 purchases from Instant Checkmate. On

or about September 9,2015, JI made a debit card purchase at the Potsticker House

in Chicago, Illinois, nine days prior to his September 18, 201"5 purchase from Instant

Checkmate. According to JI's Treasury Enforcement Communications System

(TECS) records, JI's last international travel was the trip from Chicago to Beijing

from December 22, z}ir/-to Februa ry, 3, 2lLl,noted above.

26. According to information obtained from law enforcement databases, all

eight individuals referenced in the background check documents were naturalized

U.S. citizens born in Taiwan or China now living in the United States. All eight

individuals either currently worked in or were recently retired from a career in the

science and technolory industry, including several individuals specializing in

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aerospace fields. Open source research indicated that as of approximately January

2018, at least seven of the eight individuals worked for, or had recently retired from,

cleared U.S. defense contractors.

27. Based upon my training and experience, it appears that JI was tasked
by Intelligence Officer A to provide him with biographical information on eight
individuals for possible recruitment by the JSSD. JI attempted to cover up the work

he was doing on behalf of Intelligence Officer A by misrepresenting the contents of

the attachments calling them "Midterm Test Questions" rather than stating the true

contents of the email - background checks on ethnic Chinese working as engineers

and scientists, including for cleared U.S. defense contractors. In my training and

experience, it is typical tradecraft for Chinese intelligence officers to instruct their

U.S. assets to conceal information they are providing to their handlers in China in

order to protect that information, the asset, and the intelligence officer.

Undereoaer Meeting with JI CHOAQUN

28. On or about April 25,20L8, JI met with an individual who, unbeknownst

to JI, was an FBI Special Agent working undercover (the "UC"). During the audio and

video recorded first meeting between JI and the UC, the UC introduced himself to JI

as someone directed to meet with JI by Intelligence Officer C in light of Intelligence

Officer A's arrest.8

8 Based upon the review of the SMS database text messages, agents believe that
Intelligence Officer C is the direct supervisor of Intelligence Officer A at the JSSD. More
specifrcally, in the majority of messages in which Intelligence Officer A either communicates
directly with or references Intelligence Officer C, he uses Intelligence Officer C's formal title.

1"1
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29. On or about J0.[ay 17,20L8, JI met with the UC a second time. During

the audio and video recorded meeting, JI made multiple statements that corroborated

the information revealed during the course of the investigation and detailed above.

30. For example, JI explained that he was first introduced to Intelligence

Officers A and B via Intelligence Officer C, who he met during a recruitment fair
while in school in China. He stated he believed Intelligence Officers A, B, and C were

in the same "confidential unit" and further explained as follows:

Initially when I met [Intelligence Officer C], it was during a recruitment

fair in the IM [phoneticl school. There was not much advertising. They
were asking if anyone was interested in joining the organization. They
said it was a confidential unit but they did not elaborate. Therefore, I
went there and met llntelligence Officer C]. Afterwards, [Intelligence
Officer C] asked [Intelligence Officer B] to contact me in Beijing because
[Intelligence Officer B] was in Beijing during that period of time. It was
during my Nanjing trip that I met llntelligence Officer A] for the first
time when he was together with [Intelligence Officer C]. . . It was when
I was in Beijing I contacted [Intelligence Offrcer B] for a few times. I
often dined with him. He told me stories such as Long-Tan-San-Jie the
three covert CCP agents inside KMT. Afterwards, I went to Nanjing to
look for and meet [Intelligence Officer A]. AJterwards, when I first left
China, it was [Intelligence Officer B] who contacted me using my
undergraduate name and my newly registered email address.e

Based on my training and experience, using the formal title is a sign of respect and indicates
that Intelligence Officer C holds a higher rank than Intelligence Officer A.
e Based on my training and experience, and information obtained from publicly available
sources, "Long Tan San Jie" verbatim translates to "three heroes of the dragon's lair," but is
colloquially a reference to a Chinese intelligence operation conducted in the late 1920s.
Considered one of the earliest modern examples of a Chinese "seeding operation," the Chinese
Communist Party (CCP) directed three spies to infrltrate the CCP's main rival political party,
the Kuomintang (KMT). The three spies successfully gained employment with and access to
sensitive KMT information and provided crucial warning to the CCP during the peak of the
KMT's violent suppression of the CCP in 1931.

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31. JI further explained that he had more contact with Intelligence

Officer B at first because he went to undergraduate school in Beijing, which is where

he understood Intelligence Officer B was based. He began communicating with

Intelligence Officer A because, according to Intelligence Officer A, Intelligence

Officer B was transferred to a different department.

32. JI further explained that Intelligence Officer A asked him to purchase

background checks on a few people from the internet. He explained that "they just

wanted me to purchase some documents on their behalf. Their reason was just

because it was inconvenient for them to make payments from China." Based on my

training and experience, I believe that Intelligence Officer A tasked JI with

purchasing these background check reports because Intelligence Officer A was
(a) using operational security tradecraft by not generating a subscriber and payment

trail in China with the U.S.-based background check companies; and (b) was testing

JI's skills as a potential asset by tasking him to purchase these background check

reports.

33. JI further explained that the "people search website would tell you the
price of a report per person," which appeared to be a reference to the background

check reports JI purchased from Intelius, Instant Checkmate, and Spokeo. JI stated
that he "purchased the documents after [he] came to the U.S," and that he paid
approximately $ZOO for the reports. He further stated that Intelligence Officer A

asked how he could send the money to JI after JI purchased the background check

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documents, and JI provided Intelligence Officer A with an account number. He

further stated that sometime thereafter he was reimbursed approximately $1,OOO.

34. JI further stated that he labeled the file containing the reports "Mid
Term Quiz Questions," and. sent the reports to both Intelligence Officers A and B via

email, which is consistent with the emails discovered in Subject Account 1.

35. According to records checks conducted by the Department of Justice

Foreign Agents Registration Unit, as of June L4,2018, JI did not provide notice to
the Attorney General of the United States of his actions or intentions to act as an

agent of a foreign government or foreign officiaI.

36. Based on the foregoing, I believe that JI acted as an agent of the Chinese

government by agreeing to taskings from Chinese intelligence officers, and in

particular, by obtaining background checks in the United States on ethnic Chinese

individuals working for cleared U.S. defense contractors in the United States at the

request of Intelligence Officers A, B, and C. By collecting this information for an arm

of the Chinese government while in the United States, JI knowingly and unlawfully

acted as an agent of a foreign power.

JI CHAOQUN and the MAVNI Progrann

37. In May 2016, JI enlisted in the U.S. Army Reserves as an E4lSpecialist

under the Military Accessions Vital to the National Interest program ("MAVNI")

program.lo

10The MA\N program authorizes the U.S. Armed Forces to recruit certain legal aliens
whose skills are considered to be vital to the national interest. Individuals such as physicians,

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38. On or about June 6,20L6, as part of the process for his application to

participate in the MATINI program, JI electronically submitted Standard Form 86

("SF-86"), a Security Clearance Application.

39. In Section 20B of the SF-86, JI answered "No" to the following question:

Have you or any member of your immediate family in the past seven
years had any contact with a foreign government, its establishment
(such as embassy, consulate agency, military service or security service,
etc.) or its representatives, whether inside or outside the U.S.? (Answer
'No' if the contact was routine visa applications and border crossings
related to either official U.S. Government travel or foreign travel on a
U.S. passport.)

40. On or about December 6,20L7, also as part of the process for his MA'\rNI

application, JI underwent a Single Scope Background Investigation ("SSBI")

interview with a U.S. Army officer. As part of the interview, the officer reviewed JI's

responses in the SF-86 with JI. During the interview, JI again failed to disclose his

relationship and contacts with Intelligence Officers A, B, or C. At the conclusion of

the interview, JI signed a Department of the Army Form 2823,which is a sworn

statement affirming to the truthfulness of the information JI provided during his

interview.

nurses, and experts in certain languages with associated cultural background become eligible
if they meet the following requirements: candidates must be in the country legally, must have
been in valid status for at least two years immediately prior to the enlistment date, and
applicants who may be eligible on the basis of a nonimmigrant status category must not have
any single absence from the United States of more than 90 days during the two-year period
immediately preceding the date of enlistment. Once the immigrant enlistees complete the 10-
week Basic Combat Training, their citizenship application will be expedited without frrst
obtaining lawful permanent residence.

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4L. Based upon the above-described contacts between JI and Intelligence

Officer A in China and via e-mail, JI's responses to the SF-86 Section 20B question

and during his SSBI interview were materially false representations.

Conclusion

42. Based on the foregoing, I believe there exists probable cause to believe

that from on or about August 28,20L3, through on or about September 21,2018, Jl

CHAOQUN, did knowingly act in the United States as an agent of a foreign

government, specifically the People's Republic of China, without prior notification to

the Attorney General, as required by law, in violation of fitle 18, United States Code,

Section 951(a).

FURTHER AFFIANT SAYETH NOT.

ANDREW K. MCKAY, Special

Federal Bureau of Investigation

SWORN to before me on September 21,2018.

United States Magistrate Judge

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