San Francisco, California - A criminal complaint was unsealed Wednesday in federal court charging Seymur Khalilov, Ramil Heydarov, and Orkhan Aliyev with conspiracy to commit wire fraud, announced Acting United States Attorney Stephanie M. Hinds, Homeland Security Investigations Special Agent in Charge Tatum King, and Federal Bureau of Investigation Special Agent in Charge Craig D. Fair.

According to the complaint, between 2016 and the present, Khalilov, 32; Heydarov, 31; and Aliyev, 31, all of San Jose, conspired to purchase high-mileage vehicles, roll back the odometers, and falsify documentation to make the vehicles appear newer.  The co-conspirators then allegedly sold the vehicles on Craigslist at significant profits.  The complaint alleges defendants fraudulently sold at least a dozen vehicles in this way for a total of at least $300,000.  In addition, the complaint states that the number of cars and amount of money at issue will likely change as the ongoing investigation into the scope and extent of the scheme continues. 

The complaint describes the multiple steps taken by the coconspirators to defraud purchasers of the cars.  For example, the complaint describes how defendants purchased high-mileage or old-model vehicles and then, with the assistance of other co-conspirators, rolled back the odometers of the vehicles.  Further, the defendants altered documentation related to the vehicles, including titles and registrations, to reflect the lower mileage amount and other fraudulent information.  The complaint alleges the fraudulent alterations were made with the goal of increasing the prospective sale price of the vehicles.  In addition, when selling the vehicles, the defendants portrayed themselves as the prior owners of the vehicles, including by altering California identification cards, so that the defendants’ true names would not appear in the vehicles’ transaction history. 

Each defendant is charged with one count of conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349.  The conspiracy charge carries a maximum statutory penalty of up to 20 years in prison and a $250,000 fine.  However, any sentence following conviction would be imposed by the court only after consideration of the U.S. Sentencing Guidelines and the federal statute governing imposition of a sentence, 18 U.S.C. § 3553.

The charges contained in the criminal complaint are mere allegations.  As in any criminal case, the defendants are presumed innocent unless and until proven guilty in a court of law.

The defendants each made their initial federal court appearance earlier today before U.S. Magistrate Judge Thomas S. Hixson.   Aliyev’s next court date is May 6, 2021, and Khalilov and Heydarov’s next court date is May 7, 2021.

Assistant U.S. Attorney Ankur Shingal is prosecuting the case with the assistance of Marina Ponomarchuk and Soana Katoa.  The prosecution is the result of an investigation by Homeland Security Investigations and the Federal Bureau of Investigation with assistance from the California Department of Motor Vehicles Investigations Division in Vallejo, the San Ramon Police Department, and the National Highway Transportation Safety Administration Office of Odometer Fraud Investigations.