Beginning in approximately November 2019, a confidential source cooperating with law enforcement began working as a salaried employee of Versus in various roles of increasing responsibility. The confidential source's duties included, among other things, vetting the qualifications of sellers wishing to sell drugs on Versus, mediating disputes between buyers and sellers, and responding to messages submitted by marketplace users. This confidential source remained a Versus moderator until the marketplace ceased operations in May 2022.

The confidential source worked directly with an individual who used the aliases “William Gibson” and “PapaLegba.” “William Gibson” identified himself in private statements to the confidential source and in public messages as one of the co-founders of Versus. For example, around May 2022, after a hacker claimed to have found a vulnerability in Versus, “William Gibson” publicly announced the decision to shut down Versus on a website. In the public message, “William Gibson” wrote, “Once we identified the vulnerability, we were at a crossroads: rebuild and come back stronger (as we had done before) or bow out gracefully. After much consideration, we have decided on the latter. We built Versus from nothing and operated it for 3 years.”

“William Gibson” communicated with the Confidential Source, among other things, through an encrypted messaging application and the messaging feature of the Versus platform. The same individual who used the handle “William Gibson” in the Versus messaging system corresponded with the Confidential Source through an encrypted messaging application, relying on the fact that “William Gibson” used the Versus messaging feature to provide the Confidential Source with a unique ID—a sequence of letters and numbers—so that the Confidential Source could identify and communicate with this same individual on the encrypted messaging application.

The user of these aliases performed multiple different operational roles at Versus. “William Gibson” was the public face of Versus, whose goal was to promote the marketplace. When Versus was a relatively new marketplace, “William Gibson” posted about Versus on a dark web forum to promote the marketplace and respond to user concerns, criticisms, and requests for help about Versus. “William Gibson” was in charge of marketing and developing a business plan for Versus. William Gibson purchased advertisements for Versus on dark web forums and instructed the Confidential Source to hire staff whose responsibilities would be to promote Versus on this same dark web forum.

Based on his review of information from the confidential source and law enforcement authorities on the Versus platform, “William Gibson” handled Versus’s daily tasks, such as responding to ticket requests, resolving disputes between customers and sellers, and reviewing seller requests. Tickets were generated by users, who requested assistance from Versus staff with their issues. These issues were often technical and involved, for example, how to complete transactions or make payments on the platform. Dispute resolution typically involved issues between sellers and customers in which, for example, a seller failed to ship narcotics as promised, shipped substandard narcotics, or sold a customer stolen credentials that were invalid. Sellers filed requests for exemption from a requirement that they pay a non-refundable bond to sell products on Versus, and “William Gibson” reviewed those requests.

Sometime shortly after May 3, 2020, “William Gibson” delegated responsibility for these tasks to Versus staff, but even then, he recommended how the requests should be resolved. For example, the Confidential Source had numerous conversations with “William Gibson” about how to adjudicate disputes and vendor requests. On or about February 13, 2021, “William Gibson” recommended to the Confidential Source how to handle a dispute when the client alleged that an order of 10 kilograms of amphetamines had been filled with sugar as a counterfeit product.

“William Gibson” created and sold a system for sellers to purchase advertising space for their products on Versus, in addition to taking other steps to promote the use of Versus to sell illegal goods. For example, on June 13, 2021, “William Gibson” explained to the Confidential Source that he had just given free advertising space on Versus to a “wholesale” seller because “that’s exactly the type of seller we’re looking for” on Versus. Based on my training and experience, “William Gibson’s” extensive interactions with the Confidential Source, and the terms “William Gibson” used to advertise Versus to potential sellers on black market forums, I believe that a “wholesale” seller is a seller who sells significant quantities of illegal drugs.

The virtual currency wallets associated with Versus traded cryptocurrency valued at millions of US dollars. For example, four Bitcoin wallets received bonus payments from vendors, commission fees, and were used to pay the confidential source's salary, negotiated at approximately 92 Bitcoins. These four wallets do not represent the total number of Bitcoin wallets trading cryptocurrency on behalf of Versus. However, depending on the value of the Bitcoin, the 92 Bitcoins represent up to $5,895,728 US dollars.

According to the confidential source and legally obtained screenshots of Versus platform activities, “William Gibson” handled the day-to-day operations of the Versus website. These responsibilities included reviewing and approving potential sellers and resolving complaints where, for example, sellers failed to ship drugs as promised, shipped substandard drugs, or sold stolen credentials that did not perform as advertised. For example, as described in paragraph 22, on or about February 13, 2021, “William Gibson” oversaw the resolution of a dispute in which a customer alleged that an order for 10 kilograms of amphetamines had been filled with counterfeit product.

The law enforcement investigation also revealed that “William Gibson” hired, organized, supervised, managed, and paid multiple individuals operating Versus through a series of recurring Monero and Bitcoin transactions. “William Gibson” paid the Confidential Source in Monero and explained that “William Gibson” paid wages in Monero to evade identification by law enforcement. On April 7, 2021, “William Gibson” told the Confidential Source about a Versus employee’s request to be paid weekly instead of monthly, and “William Gibson” explained to the Confidential Source that the reason he pays employees monthly is because he “launders the coins a [sic] few times a month.” “William Gibson,” he added, “we don’t pay in [Bitcoin] so we don’t leave any traces. That’s good for you because you get already cleaned coins and you don’t have to worry about that and it’s good for the market in general not trusting someone else to clean your coins for you.” “William Gibson” further told the confidential source, “I mean I would totally trust you to keep it safe but this guy will 100% screw up if I send him dirty [Bitcoin], which would get him caught or at least expose him, which in turn poses a threat to the entire operation.”

Finally, “William Gibson” designed a forum used to communicate on Versus, decided which products and services could be sold on Versus, directly mediated disputes involving buyers who claimed they had not received the narcotics they tried to purchase through Versus, and developed the multi-signature escrow system used to ensure sales payments could be confidently sold on the marketplace. “William Gibson” knew that Versus existed to facilitate the sale of illegal goods. On January 9, 2021, “William Gibson” told the Confidential Source how “William Gibson” feared that Versus had been discovered so he shut down the network before realizing there was “nothing to worry about,” but that he preferred to cause a “false alert rather than feel stupid in prison for not doing something.”

Between approximately November 2019 and May 2022, while SCHMITZ operated and promoted Versus with his co-conspirators, law enforcement seized approximately 2.6 kilograms of heroin ordered and shipped through Versus. Additionally, in or about September 2020, law enforcement's investigation revealed that a Versus customer had ordered seven grams of heroin for delivery to an address in the United States. On another occasion, in May 2022, a seller used Versus to offer for sale a quarter of a kilogram of cocaine for delivery from one location in the United States to another location in the United States. The buyer in this transaction paid 33 Monero, of which approximately 1.13 Monero was a commission paid to Versus. The law enforcement investigation also revealed that, around September 2020, multiple transactions occurred through Versus in which stolen credit card information was sold for cryptocurrency, and multiple identification documents were purchased through Versus, including images of legitimate U.S. passports and driver's licenses. For example, on or about October 13, 2020, an undercover law enforcement officer used Versus to purchase a list of U.S. credit card data and a separate list of scans of official government identification documents, such as U.S. passports and driver's licenses.

First, law enforcement authorities established this connection based on a comparison of statements made by “William Gibson” on a dark web forum and identified identical and unique terms used by another nickname, or alias, that law enforcement authorities have connected to SCHMITZ. For example, law enforcement analyzed approximately two million posts on a dark web forum and determined that two specific words, which are terms that appear in a fictional trilogy to which “William Gibson” frequently referenced, were used by only three users: “William Gibson,” “CypherPhreak,” and “MrCeline.” Both “CypherPhreak” and “MrCeline” are believed to have been created or controlled by SCHMITZ based on the results of further law enforcement investigation.

Second, shortly after “William Gibson” told the Confidential Source that he was going to use a new online moniker, “PapaLegba,” SCHMITZ, using an online account in his real name, purchased merchandise identified as “Papa Legba.” Specifically, on or about May 24, 2022, “William Gibson” contacted the Confidential Source using the moniker “PapaLegba” and instructed the Confidential Source to contact him through this new moniker. Based on records obtained from an online merchant, law enforcement authorities learned that SCHMITZ used an account registered in his real name to purchase a Papa Legba-themed pendant on June 13, 2022, with a credit card in his real name.

Third, law enforcement obtained a search warrant for email accounts (Account 1 and Account 2) hosted with a U.S. service provider (Provider 1). Authorities determined that Account 1 and Account 2 were used by Schmitz because, among other things, they contained emails addressed to Schmitz in his real name, and Account 2 was also used to register an account with a cryptocurrency exchange in Schmitz's real name, using Schmitz's German passport number C2GNZ8K95 to verify his identity.

Provider-1 notified U.S. authorities that, on or about November 3, 2023, Provider-1 notified the user of Account-1 that the provider had received and responded to legal process related to the account after the expiration of a nondisclosure order. The results of the criminal search warrants directed at Account-1 and Account-2 revealed that approximately two weeks later, on or about November 18, 2023, the user of Account-2 sent an email message containing only the name of a book; the name of that book contains the online nickname the Confidential Source used to communicate with William Gibson in its title. Furthermore, on November 18, 2023, Schmitz stopped communicating with the Confidential Source using the nicknames “William Gibson” and “PapaLegba.” Based on my training and experience, I believe Schmitz believed he was under investigation for his activities at Versus based on the November 3, 2024, notification from Vendor-1, and that he had identified the confidential source as a government agent.

Fourth, law enforcement authorities have identified at least two cryptocurrency transactions that support the conclusion that SCHMITZ had transferred cryptocurrency from a personal account registered in SCHMITZ's real name to be used by "William Gibson" to make the Confidential Source's salary payments for the Confidential Source's work at Versus. For example, on or about April 15, 2021, a currency exchange account registered in SCHMITZ's real name received exactly 15 Moneros worth of cryptocurrency. On or about April 17, 2021, "William Gibson" told the Confidential Source that he would receive his monthly salary "today or tomorrow." On or about April 20, 2021, the Confidential Source received exactly 15 Moneros worth of cryptocurrency into a wallet that the Confidential Source had provided to "William Gibson." Based on my training and experience, I believe that SCHMITZ likely transferred Monero cryptocurrency from a Versus wallet to a wallet under SCHMITZ's personal control on or about April 15, 2021, to reimburse himself for salary costs that SCHMITZ had subsequently paid to the Confidential Source.

Fifth, law enforcement authorities have identified numerous connections between “William Gibson” statements to the confidential source and themes, names, and accounts used by SCHMITZ. Among many other examples, “William Gibson” frequently referred to characters or themes from a particular author’s fictional publications in conversations with the confidential source. U.S. authorities lawfully obtained information from U.S. service providers that revealed purchases delivered to, or information stored on, accounts used by SCHMITZ in his real name and/or delivered to his residence in Colombia that are books by or related to this author. Additionally, U.S. authorities have identified a social media account identified by a username that is one of the characters in these fictional works, believed to be used by SCHMITZ, based on the fact that this social media account follows the account of a known Colombian associate of SCHMITZ, which contains photographs of this associate and SCHMITZ together.

Sixth, information obtained in response to lawfully obtained criminal search warrants issued by the United States has identified numerous connections between statements made by “William Gibson” and actions taken by Schmitz. For example, on one particular date, “William Gibson” informed the confidential source that he would not be available for communication because he was leaving in a few hours and would be available in a week. U.S. authorities have reviewed information lawfully obtained from Provider-1, which reveals that an account used by Schmitz contained a travel itinerary for a trip scheduled to depart the day after the above statement and return in approximately one week.