完了！精人北航校友因签证欺诈（隐瞒北航学经历）来美学习航天被逮捕
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Re: 完了！精人北航校友因签证欺诈（隐瞒北航学经历）来美学习航天被逮捕
United States of America
y. Case No. amr-5 14
JIAXUEMO ZHANG
Defendant
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
Between in or around June 2021 and on or about July 25, 2023, in the Western District of New York, and
elsewhere, the defendant, JIAKUEMO ZHANG, did knowingly utter, use, attempt to use, and possess a
non-immigrant visa, that is, an F-1 student non-immigrant visa, which the defendant knew to be falsely made,
procured by means of a false claim and statement, and otherwise procured by fraud.
All in violation of Title 18, United States Code, Section 1546(a).
This Criminal Complaint is based on these facts:
Continued on the attached sheet.
4
JES
Complainant ’s signature
BENJAMIN DANZIGER
TASK FORCE OFFICER
FEDERAL BUREAU OF INVESTIGATION
Printed name and title
Sworn to before me and signed telephonically.
Date: July £2 , 2023 Matt | \ C2 ane
Judge's signature
HONORABLE MICHAEL J. ROEMER
City and State: Buffalo, New York UNITED STATES MAGISTRATE JUDGE
Printed name and title
Case 1:23-mj-05144-MJR Document1 Filed 07/26/23 Page 2 of 8
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Benjamin Danziger, being first duly sworn, hereby depose and state as follows:
INTRODUCTION AND AGENT BACKGROUND
1. I make this affidavit in support of a criminal complaint charging JAXUEMO
ZHANG (hereinafter “ZHANG”), with a violation of Title 18, United States Code, Section
1546(a) (visa fraud).
2. Iam an Officer with U.S. Customs and Border Protection (CBP) and have
been so employed since approximately June of 2012. Since approximately February of 2021,
Ihave served as a Task Force Officer (TFO) with the Federal Bureau of Investigation in
Buffalo, New York. J have been assigned to a Counter-Intelligence Squad for the duration of
my time as a TFO. As a CBP Officer, I am responsible for enforcing immigration and
customs laws. As a TFO, I am responsible for investigating crimes related to the national
security threat posed by China. I have approximately two years of experience investigating
counterintelligence threats posed by China.
3. The facts set forth below are based upon my personal observations, my
training and experience, and information obtained during the course of the investigation
from other members of law enforcement, involving the review of records, interviews of
witnesses, and information and reports provided. Because this affidavit is submitted for the
purpose of establishing probable cause to support the issuance of a Criminal Complaint and
Arrest Warrant, I have not included each and every fact known by the government for this
investigation.
Case 1:23-mj-05144-MJR Document 1 Filed 07/26/23 Page 3 of 8
PROBABLE CAUSE
4, ZHANG is a Chinese national who has, since 2021, studied at the State
University of New York at Buffalo (U.B.) under an F-1 non-immigrant visa issued by the
U.S. Department of State.
5. On or about June 24, 2021, ZHANG submitted an application for an F-1
student non-immigrant visa at the U.S. Embassy in Beijing, China. In his visa application,
ZHANG stated that he would be attending U.B. and would be majoring in aerospace
engineering.
6. As described below, I have reviewed ZHANG’s visa application and
determined that it omitted material information about ZHANG’s education history and
research activity in China. In determining the materiality of ZHANG’s false statements, I
have been assisted by U.S. Department of State Diplomatic Security Service Special Agent
Andrew Wright (SA Wright). SA Wright has expertise on the visa application process, as
well as the documents that ZHANG provided to the U.S. Department of State in support of
his F-1 visa application.
7. [have reviewed ZHANG’s non-immigrant visa application. This application
and all associated documents were provided to me by SA Wright. SA Wright accessed these
documents through the U.S. Department of State Consular Consolidated Database (CCD)
and provided copies of all documents that ZHANG submitted to the U.S. Department of
State in support of his visa application. Included in these documents were ZHANG’s visa
application; ZHANG’s admission letter from U.B.; ZHANG’s proposed advisor’s
curriculum vitae (CV); ZHANG’s study plan; and ZHANG’s CV. ZHANG electronically
2
Case 1:23-mj-05144-MJR Document 1 Filed 07/26/23 Page 4 of 8
signed this application on June 5, 2021. By doing so, he affirmed that all of his answers were
true and complete. All documents included in a visa application are considered when the
Department of State adjudicates the visa application.
8. As a part of the student visa application process, the applicant is required to
disclose all prior educational institutions that the applicant has attended. ZHANG identified
three such institutions: (1) Quanzhou Experimental Middle School, in Fujian, China, which
he attended from September 2007 — July 2010; (2) Quanzhou Number 5 High School, in
Fujian, China, which he attended from September 2010 — June 2013; and (3) China
University of Mining and Technology Beijing, in Bejing, China, which he attended from
September 2014 — June 2018. ZHANG disclosed no other work, education, or training on
his visa application.
9. As part of his visa application, ZHANG provided a copy of his CV. This CV
identifies ZHANG as having attended the China University of Mining and Technology
Beijing (CUMTB), Quanzhou NO.5 High School, and Quanzhou Experimental Middle
School. The CV identified no other schools ZHANG had attended.
10. Because of ZHANG’s field of study and nationality, a Security Advisory
Opinion (SAO) was required and conducted based on the information ZHANG provided.
The SAO is a U.S. Government mechanism to coordinate third-agency checks on visa
applicants about whom the State Department has security-related concerns. ZHANG’s visa
was eventually approved based on the information he provided to the U.S. Department of
State.
Case 1:23-mj-05144-MJR Document1 Filed 07/26/23 Page 5 of 8
11. On or about August 26, 2021, ZHANG used his F-1 non-immigrant visa to
apply for admission to the United States at John F. Kennedy Airport. ZHANG began
attending U.B. in the fall 2021 semester.
12. During the course of my investigation, I became aware that ZHANG’s visa
application omitted part of his educational and research history. Specifically, I learned that,
in or around December 2022, ZHANG had applied for PhD programs in aerodynamics at
Purdue University, the University of Minnesota, and the University of Michigan. As part of
my investigation, I obtained copies of ZHANG’s applications to each of these universities.
13. Each of these applications contained a version of ZHANG’s CV that was
different from the CV that ZHANG had submitted to the U.S. Department of State with his
visa application. Specifically, each CV stated that, from September 2017 — December 2019,
ZHANG had conducted research and studied at Beihang University in China. Beihang
University is known to conduct research on behalf of the Chinese People’s Liberation
Army. According to his CV, while at Beihang University, ZHANG conducted research in
the Fluid Mechanics Key Laboratory of Education Ministry and the National Laboratory
for Computational Fluid Dynamics.
14. In the statement of purpose ZHANG submitted with his PhD application to
Purdue University, ZHANG discussed auditing at Beihang University and conducting
research in the National Computational Fluid Dynamics Laboratory and the Education
Ministry’s Fluid Mechanics Key Laboratory. Specifically, ZHANG wrote that, “[iJn the
National Computational Fluid Dynamics Laboratory of Beihang University, we applied
commercial software to simulate the flow fields of hypersonic vehicles and completed the
4
Case 1:23-mj-05144-MJR Document1 Filed 07/26/23 Page 6 of 8
analysis of their aerodynamic characteristics.” The National Computational Fluid
Dynamics Laboratory was jointly founded by Beihang University and the 29th Base of the
Academy of Military Sciences.
15. According to his CV, during his time at Beihang University, ZHANG was
mentored by Chongwen Jiang, Jinjun Wang, and Zhenxun Gao.
16. According to open-source information, Chongwen Jiang is the Deputy
Director of the Military Research Office at Beihang University. Included in ZHANG’s PhD
applications to the University of Minnesota, Purdue University, and John’s Hopkins
University was a letter of recommendation authored by Zhenxun Gao. The signature block
of Gao’s letter of recommendation identifies Gao as an Associate Professor and Vice
Director of the Institute of Fluid Dynamics at Beihang University.
17. Through my research and experience, I am aware that Beihang University is
designated as one of China’s “Seven Sons of National Defense.” Beihang University houses
nine major Chinese defense laboratories, to include the National Laboratory of
Computational Fluid Dynamics. Open-source information indicates that this laboratory was
jointly established with the 29th Base of the Academy of Military Sciences. In both the
statement of purpose and CV that ZHANG submitted to Purdue University, ZHANG
reported that he conducted research in this national laboratory.
18. On May 29, 2020, the President signed Presidential Proclamation 10043,
which was entitled “Suspension of Entry as Nonimmigrants of Certain Students and
Researchers From the People’s Republic of China (PRC).” In pertinent part, this
Proclamation states:
Case 1:23-mj-05144-MJR Document 1 Filed 07/26/23 Page 7 of 8
The entry into the United States as a nonimmigrant of any national of the PRC
seeking to enter the United States pursuant to an F or J visa to study or
conduct research in the United States, except for a student seeking to pursue
undergraduate study, and who either receives funding from or who currently is
employed by, studies at, or conducts research at or on behalf of, or has been
employed by, studied at, or conducted research at or on behalf of, an entity in
the PRC that implements or supports the PRC’s ‘military-civil fusion strategy’
is hereby suspended and limited subject to section 2 of this proclamation. For
the purposes of this proclamation, the term ‘military-civil fusion strategy’
means actions by or at the behest of the PRC to acquire and divert foreign
technologies, specifically critical and emerging technologies, to incorporate
into and advance the PRC’s military capabilities.
Individuals who have a current or prior affiliation to, among other schools,
Beihang University are prohibited from entering the United States by this
proclamation.
19. After reviewing the associated data in the CCD, as well as the
paperwork ZHANG submitted in support of his June 2021 student visa application,
and after comparing that information with information ZHANG included in more
recent versions of his CV, SA Wright advised your affiant that 7HANG’s F-1 visa
application would have been denied had ZHANG disclosed that he had attended
Beihang University or conducted research at the People’s Republic of China
Education Ministry’s Fluid Mechanics Key Laboratory.
CONCLUSION
Based on the foregoing, I respectfully submit that there is probable cause to believe
that JAXUEMO ZHANG did violate Title 18, United States Code, Section 1546(a) (visa
fraud). I respectfully request that the Court issue the attached criminal complaint, as well as
Case 1:23-mj-05144-MJR Document1 Filed 07/26/23 Page 8 of 8
an arrest warrant. To allow the warrant to be effectuated, I respectfully request that the
criminal complaint, this affidavit, and the arrest warrant remain under seal.
Respectfully submitted,
fp fe a>
“Benjamin Dafiziger
Task Force Officer
Federal Bureau of Investigation
y. Case No. amr-5 14
JIAXUEMO ZHANG
Defendant
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
Between in or around June 2021 and on or about July 25, 2023, in the Western District of New York, and
elsewhere, the defendant, JIAKUEMO ZHANG, did knowingly utter, use, attempt to use, and possess a
non-immigrant visa, that is, an F-1 student non-immigrant visa, which the defendant knew to be falsely made,
procured by means of a false claim and statement, and otherwise procured by fraud.
All in violation of Title 18, United States Code, Section 1546(a).
This Criminal Complaint is based on these facts:
Continued on the attached sheet.
4
JES
Complainant ’s signature
BENJAMIN DANZIGER
TASK FORCE OFFICER
FEDERAL BUREAU OF INVESTIGATION
Printed name and title
Sworn to before me and signed telephonically.
Date: July £2 , 2023 Matt | \ C2 ane
Judge's signature
HONORABLE MICHAEL J. ROEMER
City and State: Buffalo, New York UNITED STATES MAGISTRATE JUDGE
Printed name and title
Case 1:23-mj-05144-MJR Document1 Filed 07/26/23 Page 2 of 8
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Benjamin Danziger, being first duly sworn, hereby depose and state as follows:
INTRODUCTION AND AGENT BACKGROUND
1. I make this affidavit in support of a criminal complaint charging JAXUEMO
ZHANG (hereinafter “ZHANG”), with a violation of Title 18, United States Code, Section
1546(a) (visa fraud).
2. Iam an Officer with U.S. Customs and Border Protection (CBP) and have
been so employed since approximately June of 2012. Since approximately February of 2021,
Ihave served as a Task Force Officer (TFO) with the Federal Bureau of Investigation in
Buffalo, New York. J have been assigned to a Counter-Intelligence Squad for the duration of
my time as a TFO. As a CBP Officer, I am responsible for enforcing immigration and
customs laws. As a TFO, I am responsible for investigating crimes related to the national
security threat posed by China. I have approximately two years of experience investigating
counterintelligence threats posed by China.
3. The facts set forth below are based upon my personal observations, my
training and experience, and information obtained during the course of the investigation
from other members of law enforcement, involving the review of records, interviews of
witnesses, and information and reports provided. Because this affidavit is submitted for the
purpose of establishing probable cause to support the issuance of a Criminal Complaint and
Arrest Warrant, I have not included each and every fact known by the government for this
investigation.
Case 1:23-mj-05144-MJR Document 1 Filed 07/26/23 Page 3 of 8
PROBABLE CAUSE
4, ZHANG is a Chinese national who has, since 2021, studied at the State
University of New York at Buffalo (U.B.) under an F-1 non-immigrant visa issued by the
U.S. Department of State.
5. On or about June 24, 2021, ZHANG submitted an application for an F-1
student non-immigrant visa at the U.S. Embassy in Beijing, China. In his visa application,
ZHANG stated that he would be attending U.B. and would be majoring in aerospace
engineering.
6. As described below, I have reviewed ZHANG’s visa application and
determined that it omitted material information about ZHANG’s education history and
research activity in China. In determining the materiality of ZHANG’s false statements, I
have been assisted by U.S. Department of State Diplomatic Security Service Special Agent
Andrew Wright (SA Wright). SA Wright has expertise on the visa application process, as
well as the documents that ZHANG provided to the U.S. Department of State in support of
his F-1 visa application.
7. [have reviewed ZHANG’s non-immigrant visa application. This application
and all associated documents were provided to me by SA Wright. SA Wright accessed these
documents through the U.S. Department of State Consular Consolidated Database (CCD)
and provided copies of all documents that ZHANG submitted to the U.S. Department of
State in support of his visa application. Included in these documents were ZHANG’s visa
application; ZHANG’s admission letter from U.B.; ZHANG’s proposed advisor’s
curriculum vitae (CV); ZHANG’s study plan; and ZHANG’s CV. ZHANG electronically
2
Case 1:23-mj-05144-MJR Document 1 Filed 07/26/23 Page 4 of 8
signed this application on June 5, 2021. By doing so, he affirmed that all of his answers were
true and complete. All documents included in a visa application are considered when the
Department of State adjudicates the visa application.
8. As a part of the student visa application process, the applicant is required to
disclose all prior educational institutions that the applicant has attended. ZHANG identified
three such institutions: (1) Quanzhou Experimental Middle School, in Fujian, China, which
he attended from September 2007 — July 2010; (2) Quanzhou Number 5 High School, in
Fujian, China, which he attended from September 2010 — June 2013; and (3) China
University of Mining and Technology Beijing, in Bejing, China, which he attended from
September 2014 — June 2018. ZHANG disclosed no other work, education, or training on
his visa application.
9. As part of his visa application, ZHANG provided a copy of his CV. This CV
identifies ZHANG as having attended the China University of Mining and Technology
Beijing (CUMTB), Quanzhou NO.5 High School, and Quanzhou Experimental Middle
School. The CV identified no other schools ZHANG had attended.
10. Because of ZHANG’s field of study and nationality, a Security Advisory
Opinion (SAO) was required and conducted based on the information ZHANG provided.
The SAO is a U.S. Government mechanism to coordinate third-agency checks on visa
applicants about whom the State Department has security-related concerns. ZHANG’s visa
was eventually approved based on the information he provided to the U.S. Department of
State.
Case 1:23-mj-05144-MJR Document1 Filed 07/26/23 Page 5 of 8
11. On or about August 26, 2021, ZHANG used his F-1 non-immigrant visa to
apply for admission to the United States at John F. Kennedy Airport. ZHANG began
attending U.B. in the fall 2021 semester.
12. During the course of my investigation, I became aware that ZHANG’s visa
application omitted part of his educational and research history. Specifically, I learned that,
in or around December 2022, ZHANG had applied for PhD programs in aerodynamics at
Purdue University, the University of Minnesota, and the University of Michigan. As part of
my investigation, I obtained copies of ZHANG’s applications to each of these universities.
13. Each of these applications contained a version of ZHANG’s CV that was
different from the CV that ZHANG had submitted to the U.S. Department of State with his
visa application. Specifically, each CV stated that, from September 2017 — December 2019,
ZHANG had conducted research and studied at Beihang University in China. Beihang
University is known to conduct research on behalf of the Chinese People’s Liberation
Army. According to his CV, while at Beihang University, ZHANG conducted research in
the Fluid Mechanics Key Laboratory of Education Ministry and the National Laboratory
for Computational Fluid Dynamics.
14. In the statement of purpose ZHANG submitted with his PhD application to
Purdue University, ZHANG discussed auditing at Beihang University and conducting
research in the National Computational Fluid Dynamics Laboratory and the Education
Ministry’s Fluid Mechanics Key Laboratory. Specifically, ZHANG wrote that, “[iJn the
National Computational Fluid Dynamics Laboratory of Beihang University, we applied
commercial software to simulate the flow fields of hypersonic vehicles and completed the
4
Case 1:23-mj-05144-MJR Document1 Filed 07/26/23 Page 6 of 8
analysis of their aerodynamic characteristics.” The National Computational Fluid
Dynamics Laboratory was jointly founded by Beihang University and the 29th Base of the
Academy of Military Sciences.
15. According to his CV, during his time at Beihang University, ZHANG was
mentored by Chongwen Jiang, Jinjun Wang, and Zhenxun Gao.
16. According to open-source information, Chongwen Jiang is the Deputy
Director of the Military Research Office at Beihang University. Included in ZHANG’s PhD
applications to the University of Minnesota, Purdue University, and John’s Hopkins
University was a letter of recommendation authored by Zhenxun Gao. The signature block
of Gao’s letter of recommendation identifies Gao as an Associate Professor and Vice
Director of the Institute of Fluid Dynamics at Beihang University.
17. Through my research and experience, I am aware that Beihang University is
designated as one of China’s “Seven Sons of National Defense.” Beihang University houses
nine major Chinese defense laboratories, to include the National Laboratory of
Computational Fluid Dynamics. Open-source information indicates that this laboratory was
jointly established with the 29th Base of the Academy of Military Sciences. In both the
statement of purpose and CV that ZHANG submitted to Purdue University, ZHANG
reported that he conducted research in this national laboratory.
18. On May 29, 2020, the President signed Presidential Proclamation 10043,
which was entitled “Suspension of Entry as Nonimmigrants of Certain Students and
Researchers From the People’s Republic of China (PRC).” In pertinent part, this
Proclamation states:
Case 1:23-mj-05144-MJR Document 1 Filed 07/26/23 Page 7 of 8
The entry into the United States as a nonimmigrant of any national of the PRC
seeking to enter the United States pursuant to an F or J visa to study or
conduct research in the United States, except for a student seeking to pursue
undergraduate study, and who either receives funding from or who currently is
employed by, studies at, or conducts research at or on behalf of, or has been
employed by, studied at, or conducted research at or on behalf of, an entity in
the PRC that implements or supports the PRC’s ‘military-civil fusion strategy’
is hereby suspended and limited subject to section 2 of this proclamation. For
the purposes of this proclamation, the term ‘military-civil fusion strategy’
means actions by or at the behest of the PRC to acquire and divert foreign
technologies, specifically critical and emerging technologies, to incorporate
into and advance the PRC’s military capabilities.
Individuals who have a current or prior affiliation to, among other schools,
Beihang University are prohibited from entering the United States by this
proclamation.
19. After reviewing the associated data in the CCD, as well as the
paperwork ZHANG submitted in support of his June 2021 student visa application,
and after comparing that information with information ZHANG included in more
recent versions of his CV, SA Wright advised your affiant that 7HANG’s F-1 visa
application would have been denied had ZHANG disclosed that he had attended
Beihang University or conducted research at the People’s Republic of China
Education Ministry’s Fluid Mechanics Key Laboratory.
CONCLUSION
Based on the foregoing, I respectfully submit that there is probable cause to believe
that JAXUEMO ZHANG did violate Title 18, United States Code, Section 1546(a) (visa
fraud). I respectfully request that the Court issue the attached criminal complaint, as well as
Case 1:23-mj-05144-MJR Document1 Filed 07/26/23 Page 8 of 8
an arrest warrant. To allow the warrant to be effectuated, I respectfully request that the
criminal complaint, this affidavit, and the arrest warrant remain under seal.
Respectfully submitted,
fp fe a>
“Benjamin Dafiziger
Task Force Officer
Federal Bureau of Investigation
Re: 完了！精人北航校友因签证欺诈（隐瞒北航学经历）来美学习航天被逮捕
太惨了，张大磊横着进美国，北航学子被抓
美国药丸
美国药丸
Larry Zhang 写了： 2023年 8月 4日 10:04 自己傻整出漏子了
————
2021年8月26日，张佳学模从纽约肯尼迪机场入境美国，于秋季学期在水牛城大学开始就读。据他在领英上的纪录，他是水牛城大学的硕士生，对计算流体力学、高速流动物理和湍流感兴趣。
一年后的2022年12月，他向普渡大学、明尼苏达大学和密歇根大学申请空气动力学博士项目。但在这些新的博士申请中，他提交的简历与他之前向美国国务院提交的简历不一致。
具体来说，这些新的简历均注明，他在2017年9月至2019年12月在中国北京航空航天大学进行研究和学习，他谈及在北航期间还参与了流体力学教育部重点实验室和计算流体力学国家实验室的研究。调查此案的FBI探员指出，计算流体力学国家实验室由北京航空航天大学与军事科学院二十九基地联合共建。
根据张的新简历，他在北航就读期间，曾受到北航军工科研处副处长蒋崇文，以及高振勋和王金军的指导。
Re: 完了！精人北航校友因签证欺诈（隐瞒北航学经历）来美学习航天被逮捕
天大、中山、川大、人大等
i 离岸五毛心理分析大师
ii 通知你，请你删除签名档中的这个ID，lobster110。否则按照站规，如果对方一直举报，你就会被封禁。
iii ID holders originally from PRC, currently residing in the US but holding extreme anti-America views
lsheng, F250, VladPutin, UnixLinux, bigball, beijingren3
ii 通知你，请你删除签名档中的这个ID，lobster110。否则按照站规，如果对方一直举报，你就会被封禁。
iii ID holders originally from PRC, currently residing in the US but holding extreme anti-America views
lsheng, F250, VladPutin, UnixLinux, bigball, beijingren3
Re: 完了！精人北航校友因签证欺诈（隐瞒北航学经历）来美学习航天被逮捕
这不被逮捕起诉了
i 离岸五毛心理分析大师
ii 通知你，请你删除签名档中的这个ID，lobster110。否则按照站规，如果对方一直举报，你就会被封禁。
iii ID holders originally from PRC, currently residing in the US but holding extreme anti-America views
lsheng, F250, VladPutin, UnixLinux, bigball, beijingren3
ii 通知你，请你删除签名档中的这个ID，lobster110。否则按照站规，如果对方一直举报，你就会被封禁。
iii ID holders originally from PRC, currently residing in the US but holding extreme anti-America views
lsheng, F250, VladPutin, UnixLinux, bigball, beijingren3
Re: 完了！精人北航校友因签证欺诈（隐瞒北航学经历）来美学习航天被逮捕
精人今天居然未出窝
为师弟说句话
神奇！
为师弟说句话
神奇！
i 离岸五毛心理分析大师
ii 通知你，请你删除签名档中的这个ID，lobster110。否则按照站规，如果对方一直举报，你就会被封禁。
iii ID holders originally from PRC, currently residing in the US but holding extreme anti-America views
lsheng, F250, VladPutin, UnixLinux, bigball, beijingren3
ii 通知你，请你删除签名档中的这个ID，lobster110。否则按照站规，如果对方一直举报，你就会被封禁。
iii ID holders originally from PRC, currently residing in the US but holding extreme anti-America views
lsheng, F250, VladPutin, UnixLinux, bigball, beijingren3
NC CHINESE AMERICANS FOR TRUMP 