Indictment - Count One - Conspiracy 18 U.S.C.§371

Oct 3, 2026

Indictment Count One charges Peter Ghavami (also known as Peter Ghavami Lahidji), Gary Heinz, and Michael Welty with conspiracy under 18 U.S.C. §371. The document identifies relevant financial institutions, including a Swiss corporation with U.S. wholly owned subsidiaries and an SEC-registered broker-dealer and investment adviser. It describes marketing and provision of municipal bond investment agreements and related swap transactions, including roles in underwriting, investment services, and competitive bidding processes, and details the defendants’ positions and compensation linked to fees and revenues.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages41

Reading Time1 h 43 min

AccessFree to download

The Relevant Parties and Entities

Financial Institution A and Subsidiaries

Financial Institution C

Financial Institution D

Defendants and Their Roles

Case 1:10-cr-01217-JFK Document 5 Fi UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEWYORK -X UNITED STATES OF AMERICA V. UDGE KEENAN PETER GHAVAMI (aka PETER GHAVAMILAHIDJI);GARY HEINZ;and:MICHAEL WELTY, Defendants. : -------------X INDICTMENT The Grand Jury charges: COUNT ONE-CONSPIRACY(18 U.S.C.§371) 1. PETER GHAVAMI(aka PETER GHAVAMILAHIDJI),GARYHEINZ,and MICHAEL WELTY are hereby indicted and made defendants on the charge statedbelow. # THE RELEVANT PARTIES AND ENTITIES During the period covered by this Count: 2. Financial Institution A was a corporation existing under the laws ofSwitzerland with its principle place of business in Zurich,Switzerland.Financial | ec
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DATE FILED:DEC 092010. | | | --- | --- | 10CRIM1217 Filed: Violations: 18 U.S.C.§37118 U.S.C.§134318 U.S.C.§134918 U.S.C.§1512(b) Case 1:10-cr-01217-JFK Document 5 Filed 12/09/10 Page 2 of 42 Institution A maintains several wholly-owned subsidiaries in the United States,includinga financial services company (hereinafter "FSC”).Financial Institution A and FSC'sprincipal place of business in the United States are in New York,New York. 3. Directly or through its subsidiaries,including FSC,Financial Institution Amarketed financial products and services to various municipalities throughout the UnitedStates,including underwriting and investment services to various municipalities,acting asa provider for investment agreements for the proceeds of municipal bonds and as aprovider for investment agreements and other municipal finance contracts,as described inParagraphs 15 through 24 of this Count.Financial Institution A also served as a providerof financial transactions known as swaps related to investment agreements and othermunicipal finance contracts.In addition Financial Institution A and FSC acted a brokerfor investment agreements and other municipal finance contracts. 4. For purposes of this Count,Financial Institution A and FSC acted in theircapacity as a provider for investment agreements and municipal finance contracts. 5. Financial Institution A was during the relevant time period registered withthe Federal Reserve as a financial holding company and was a financial institution thatwas a branch or agency of a foreign bank,within the meaning of Title 18,United StatesCode,Section 20.During the relevant period,FSC was registered as a broker-dealer andinvestment adviser with the United States Securities and Exchange Commission(“SEC”). Case 1:10-cr-01217-JFK Document 5 Filed 12/09/10 Page 3 of 42 6. PETER GHAVAMI,aka PETER GHAVAMILAHIDJI,is a Belgian citizenand resident of Moscow,Russia.From April 1999 to March 2004,defendantGHAVAMI was employed by FSC and worked primarily in New York,New York,andfrom March 2004 to November 2007,defendant GHAVAMI was employed by FinancialInstitution A and worked primarily in London,England.From January 2001 to March2004,defendant GHAVAMI was a managing director and the co-head of the municipalbond reinvestment and derivatives(“MRD”)desk at FSC.During that time,defendantGHAVAMI's compensation,including bonus,restricted stock awards and stock options,was based on,among other things,the amount of fees and revenue generated by the MRDdesk and the number and profitability of investment agreements and other municipalfinance contracts(as described in Paragraphs 15 to 24 of this Count)awarded to FinancialInstitution A.Until March 2004,defendant GHAVAMI directly supervised defendantsGARY HEINZ and MICHAEL WELTY. 7.GARY HEINZ,a resident of Jersey City,New Jersey,was a vice presidentand a marketer on the MRD desk at FSC from February 2001 to April 2004.DefendantHEINZ's compensation,including bonus and restricted stock awards,was based on,among other things,the amount of fees and revenue generated by the MRD desk and thenumber and profitability of investment agreements and other municipal finance contra

FAQs

What charge is described in Count One?

Count One alleges conspiracy under 18 U.S.C. §371 against Peter Ghavami (also known as Peter Ghavami Lahidji), Gary Heinz, and Michael Welty.

What role did Financial Institution A and its subsidiary FSC play?

They marketed and provided municipal bond investment agreements and related financial transactions, including swaps tied to municipal finance contracts.

How does the indictment describe the defendants’ employment and compensation?

It states that Ghavami, Heinz, and Welty held senior roles on the municipal bond reinvestment and derivatives desk, and their compensation was tied to fees, revenue, and the number and profitability of municipal finance contracts.

Oct 3, 2026

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