Specifically, as set forth below, I have probable cause to believe that the defendants conspired with others known and unknown: (1) to bribe college entrance exam administrators to facilitate cheating on college entrance exams; (2) to bribe varsity coaches and administrators at elite universities to designate certain applicants as recruited athletes or as other favored candidates, thereby facilitating the applicants’ admission to those universities; and (3) to use the facade of a charitable organization to conceal the nature and source of the bribe payments.The facts set forth in this affidavit come from my personal involvement with this investigation, interviews with witnesses, including the cooperating witnesses . . . and my review of documents -- including bank records, flight records, e-mails, telephone toll records, cell site data and other materials obtained through grand jury subpoenas and search warrants -- as well as Court-authorized Title III wiretap recordings, consensual recordings made by a cooperating witness, and information provided by other law enforcement agents.
6. Beginning in or about 2011, and continuing through the present, the defendants -- principally individuals whose high-school aged children were applying to college -- conspired with others to use bribery and other forms of fraud to facilitate their children’s admission to colleges and universities in the District of Massachusetts and elsewhere, including Yale University, Stanford University, the University of Texas, the University of Southern California, and the University of California-Los Angeles, among others. Evidence I have reviewed shows that the scheme included the following:a) Bribing college entrance exam administrators to allow a third party to facilitate cheating on college entrance exams, in some cases by posing as the actual students, and in others by providing students with answers during the exams or by correcting their answers after they had completed the exams;b) Bribing university athletic coaches and administrators to designate applicants as purported athletic recruits -- regardless of their athletic abilities, and in some cases, even though they did not play the sport they were purportedly recruited to play -- thereby facilitating their admission to universities in place of more qualified applicants;c) Having a third party take classes in place of the actual students, with the understanding that grades earned in those classes would be submitted as part of the students’ college applications;d) Submitting falsified applications for admission to universities in the District of Massachusetts and elsewhere that, among other things, included the fraudulently obtained exam scores and class grades, and often listed fake awards and athletic activities; ande) Disguising the nature and source of the bribe payments by funneling the money through the accounts of a purposed charity, from which many of the bribes were then paid.
Between approximately 2011 and 2018, parents paid CW-1 approximately $25 million to bribe coaches and university administrators to designate their children as purported recruited athletes, or as members of other favored admissions categories, thereby facilitating the children’s admission to those universities. . . .CW-1 typically explained to his clients, in substance, that the scheme was a tried-and-true method of gaining admission to colleges, and that many other families were participating or had already participated in it, leveraging connections CW-1 had developed at multiple universities over years of work with prior clients. For example, set forth below is how CW-1 described the scheme to CAPLAN in the June 15, 2018 calls, during which CW-1 represented to CAPLAN that he had successfully engaged in the same scheme with nearly 800 other families: