Inside the Criminal Complaint Against Liu’s Campaign Treasurer

The criminal complaint against city Comptroller's John Liu's campaign treasurer, Jenny Hou, on fraud and obstruction charges offers a detailed account of the alleged conspiracy that could land the 25-year old in jail for 60 years.

Much the 25-page criminal complaint reflects the first-hand observations by an undercover FBI agent who posed as a businessman looking to support Liu and who knows how to use a hidden video camera.
There are also excerpts of texts and instant messages allegedly sent by Hou about how best to deceive New York City Campaign Finance Board auditors.
An unknown number of conspirators allegedly found a way to take large illegal campaign donations, divvy them into smaller amounts and pass them through so-called straw donors so the campaign would qualify for the city's generous campaign financing matching funds paid for with taxpayers money.
Liu’s name appears nowhere in the criminal compliant and, for the purpose of the document, Hou's efforts are merely described as being on behalf of a nameless "candidate." What is also instructive is just how much of the alleged criminal activity came after the first arrest in the case back in November 2011.
Here are some highlights:

  • Jenny Hou on or about July 11, 2011, "participated in a series of instant message chats" with a campaign volunteer  in which she wrote "fyi, CFB (NYCCFB) auditors look very carefully at the if you're doing that, just make sure the handwriting looks as close  to the donors (handwriting) as possible."

  • Hou and others known and unknown devised "a scheme and artifice to defraud, and for obtaining money by means false and fraudulent pretences, representations, and promises, willfully and knowingly would and did transmit and cause to be transmitted by means of wire communication in interstate and foreign commerce, writings signs, signals, pictures, and sounds for the purpose of executing such scheme and artifice." 

  • Since about December 2011, Hou “willfully, knowingly, and corruptly, did obstruct, influence, and impede official proceedings” because she failed to provide documents that she knew to be helpful to investigators, according to the complaint.

  • The complaint says records from the city’s Campaign Finance Board show “the Campaign did not disclose any bundlers or intermediaries for the 2013 New York City election cycle until January 17,2012, despite the fact that the campaign had been raising funds for the 2013 New York City election cycle since  at least in or about December 2009, and the campaign had raised approximately $2,023,572 as of February 24, 2012."

  •  "On or about August 15, 2011"  intermediary-3 "informed the  u/c (undercover FBI agent)" that intermediary -3 "had funneled large campaign contributions through straw donors for the candidate in the past" and had "collected contributions in a similar matter for another local politician, but not to the extend that Intermediary -3  had done for the candidate."

  • "the Candidate and the u/c (undercover FBI agent) then engaged in a brief discussion in which the candidate asked the u/c  abiut the u/c's business background, and the u/c expressed his desire to assist the candidate's 2013 campaign. "

Hou, Jenny Complaint