Case 1:18-cr-00238-PAB Document 1 Filed 05/17/18 USDC Colorado Page 1 of 17

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Criminal Case No. 18-cr-00238-PAB

UNITED STATES OF AMERICA,

Plaintiff,
v.

HANNO VAN RENSBURG,

Defendant.

INDICTMENT

18 U.S.C. §§ 2, 1343, 1349; 16 U.S.C. §§ 3372(a)(2)(A), 3372(a)(4), 3373(d)(1)(B),

1538(a)(1)(G), 1540(b)(1); 50 C.F.R. §§ 17.11, 17.21(e); 17.31(a); 17.40(e)(6)(ii)
______________________________________________________________________________

THE GRAND JURY CHARGES:

Background: The Regulation of Trade in Threatened or Endangered Species

At all times relevant to this Indictment:

1. The Convention on International Trade in Endangered Species of Wild Fauna and

Flora (“CITES”), was signed by the United States in 1973 and became effective in 1975.

CITES regulated the international trade in wildlife by placing species onto three “Appendices”

based on the species’ relative threatened status: species on Appendix One are the most

seriously threatened and, therefore, the most restricted; species on Appendix Two, such as the

African Elephant (Loxodonta Africana) are not as threatened and can be traded with an

appropriate permit; species on Appendix Three are those that are of concern only in a particular

country and are the least regulated.

2. The United States Fish and Wildlife Service implemented CITES in the United

States through the Endangered Species Act (“ESA”) and its associated regulations. See 50

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C.F.R. §§ 17.1(a) and 23.1(c). The ESA, 16 U.S.C. § 1538(a)(1)(G), made it unlawful to

violate any regulation pertaining to a threatened species.

3. The African Elephant (Loxodonta Africana) was listed as “threatened” under the

Endangered Species Act, which executed the CITES by establishing a program for the

conservation of endangered and threatened species designated as such by the Secretaries of the

Interior and Commerce. 50 C.F.R. § 17.11. On July 17, 2014, the United States Fish and

Wildlife Service (the “Service”) determined that the import of sport-hunted African Elephant

trophies taken in Zimbabwe on or after April 4, 2014 would not be allowed. On March 26,

2015, the Service extended the ban on the import of sport-hunted African Elephant trophies into

2015 and to all future hunting seasons until such time as the Service could obtain necessary

information about the status of Zimbabwe’s elephant population.

4. It was a violation of the ESA’s regulations to deliver, receive, carry, transport or

ship in foreign commerce, by any means whatsoever, and in the course of a commercial activity,

any threatened wildlife. See 50 C.F.R. § 17.31 (applying provisions of 50 C.F.R. § 17.21).

However, the regulations at 50 C.F.R. §17.40 contain a special rule for the African Elephant

(Loxodonta Africana).

5. The special regulations for the African Elephant made it unlawful to deliver,

receive, carry, transport or ship in interstate or foreign commerce and in the course of a

commercial activity any sport-hunted African Elephant (Loxodonta Africana) trophy. 50

C.F.R. § 17.40(e)(6)(ii). Furthermore, only trophies taken legally in an African elephant range

country qualified as sport-hunted. 50 C.F.R. § 17.40(e)(6)(i)(A).

6. The Lacey Act Amendments of 1981, 16 U.S.C. § 3371 et seq., (“the Lacey

Act”), made it unlawful for any person knowingly to, among other things, transport or sell in

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foreign commerce any wildlife which the person knows to have been taken, possessed,

transported or sold in violation of any foreign law.

7. “Wildlife” was defined in the Lacey Act to include any wild animal, including the

African Elephant, whether alive or dead, and including any part or product thereof.

8. “Taken” was defined in the Lacey Act to mean captured, killed, or collected.

9. “Sale” and Purchase” were each respectively defined to include “guiding,

outfitting, or other services.”

Background: Relevant Entities and Persons

10. HANNO VAN RENSBURG was a resident and citizen of the Republic of South

Africa (“South Africa”). He was a professional hunter who owned and operated AUTHENTIC

AFRICAN ADVENTURES, a South African company through which he marketed and sold

hunts to American citizens.

11. COLORADO HUNTER was a resident of Colorado, in the State and District of

Colorado. COLORADO HUNTER was not a resident or citizen of South Africa and did not

maintain a residence in South Africa.

12. UNDERCOVER HUNTER was a Special Agent with the United States Fish and

Wildlife Service, Office of Law Enforcement operating out of the state and District of Colorado.

13. ZIMBABWE HUNTER, whose identity is known to the Grand Jury, was a

resident and citizen of the Republic of Zimbabwe (“Zimbabwe”). ZIMBABWE HUNTER was

a professional hunter who owned and operated a Zimbabwe-based outfitting company, the

identity of which is known to the Grand Jury, through which ZIMBABWE HUNTER provided

hunting-related services, including guided hunts, dipping and packing, and the facilitation of

export permits.

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14. FACILITATOR, whose identity is known to the Grand Jury, was a resident of

New York. FACILITATOR was an employee of a New York Corporation, the identity of

which is known to the grand jury, in the business of facilitating the import of hunting trophies by

coordinating with the foreign exporter, the professional hunter, taxidermists, and shipping

companies. FACILITATOR was given a power of attorney by COLORADO HUNTER to

handle all of his importing and exporting matters.

COUNTS 1 - 3

15. In or about and between March 2015 and August 2016, both dates being

approximate and inclusive, in the State and District of Colorado and elsewhere the defendant,

HANNO VAN RENSBURG, together and with other persons known and unknown to the Grand

Jury, devised and intended to devise a scheme and artifice to defraud the Zimbabwe Parks and

Wild Life Authority by obtaining property, to wit, an export permit, by means of false and

fraudulent pretenses, representations and promises relating to COLORADO HUNTER’s

purported residence in South Africa (hereinafter “the scheme”). The scheme is further

described as follows:

I. The Fraudulent Scheme

16. HANNO VAN RENSBURG, and others, (a) sought out an opportunity to hunt the

large elephants that frequent the area around Gonarezhou National Park in Zimbabwe, (b)

retained the services of a Zimbabwe-based outfitter with access to a concession on the border of

Gonarezhou National Park, with the goal of hunting large elephants inside the park, (c) shot

several elephants, (d) fraudulently ignored the first elephant shot in order to falsely justify an

incursion into the Gonarezhou National Park to kill the largest possible elephant inside the Park,

(d) paid somewhere between $5,000 and $8,000 in bribes to Zimbabwean government officials

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in return for their permission to authorize the shooting of multiple elephants, the killing of an

elephant inside Gonarezhou National Park, and the release of the elephant’s ivory tusks, (e)

falsely represented on a “Hunting Return Form – TRAS2 Application for Hunting NP/CITES”

issued by the government of Zimbabwe that the elephant was wounded and killed outside

Gonarezhou National Park, and (f) sought to manufacture and submit to the Zimbabwe Parks and

Wild Life Authority a letter, affidavit, or document falsely stating that the elephant was hunted

by a resident of South Africa for the purpose of obtaining an export permit.

II. The Illegal Elephant Hunt Inside Gonarezhou National Park

17. HANNO VAN RENSBURG received approximately $39,195 to lead

COLORADO HUNTER on a hunt in Gonarezhou National Park COLORADO HUNTER

wired approximately $19,195 from his Colorado bank account to VAN RENSBURG in South

Africa on or about March 9, 2015 and $20,000 on or about April 20, 2015.

18. HANNO VAN RENSBURG took COLORADO HUNTER on the paid-for hunt

sometime between April 22, 2015 and May 6, 2015. During the hunt, COLORADO HUNTER

shot and wounded, but did not kill, an elephant. The hunting party, including VAN

RENSBURG, tracked the wounded elephant into Gonarezhou National Park but was ultimately

unable to find it. While inside the park, the party shot and wounded a different elephant.

While tracking that elephant, VAN RENSBURG caught the trail of yet another elephant, this one

with pus in its blood trail indicating a much older injury. VAN RENSBURG and the rest of the

party followed this trail until they found the elephant inside Gonarezhou National Park. Within

the National Park, the hunting party shot and killed this elephant, which was not the elephant that

was first wounded outside the park.

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19. After the first elephant was shot and wounded, HANNO VAN RENSBURG and

the rest of the hunting party asked the Zimbabwe Parks and Wild Life Authority for permission

to enter Gonarezhou National Park to kill the elephant. As a result, they were joined on the

hunt by several “game scouts” from the Zimbabwean government. During or after the hunt,

with the exact time being unknown, VAN RENSBURG and COLORADO HUNTER agreed to

pay and paid a bribe to the game scouts of between $5,000 and $8,000 so that they could (1)

shoot elephants other than the one that was first shot and wounded and (2) kill an elephant inside

Gonarezhou National Park, in violation of the Zimbabwe Parks and Wild Life Act.

III. The Effort to Fraudulently Obtain a Permit to Export the Illegally

Killed Elephant into South Africa

20. HANNO VAN RENSBURG worked with his client, COLORADO HUNTER, to

export the African Elephant from Zimbabwe to South Africa in violation of international and

Zimbabwean law where COLORADO HUNTER could use casts of the elephant’s tusks for his

trophy and then sell the ivory in foreign commerce.

21. On February 5, 2016, HANNO VAN RENSBURG met with COLORADO

HUNTER, to discuss, among other things, a way for COLORADO HUNTER to obtain an export

permit. In previous correspondence, ZIMBABWE HUNTER had notified COLORADO

HUNTER that COLORADO HUNTER might be able to obtain such a permit by showing that he

had a residence in South Africa. During the meeting, VAN RENSBURG and COLORADO

HUNTER discussed how they might falsely tell the Zimbabwean authorities that COLORADO

HUNTER resided with VAN RENSBURG in South Africa. To conceal this contrivance, VAN

RENSBURG quizzed COLORADO HUNTER on the layout of his house so that COLORADO

HUNTER could convincingly answer such questions and successfully represent himself as a

South African resident.

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22. As part of the process of obtaining the African Elephant from the Zimbabwe Fish

and Wild Life Authority, HANNO VAN RENSBURG and COLORADO HUNTER submitted a

hunting permit that falsely stated the elephant was killed outside of Gonarezhou National Park.

As a result of this deception, HANNO VAN RENSBURG and COLORADO HUNTER

eventually received property in the form of a CITES export permit issued by Zimbabwe on

August 26, 2016 for 4 bones, 4 feet, 3 panels, 1 cape, 1 skull and two tusks —respectively

stamped ZW2015 26037-26 and SW2015 26-38-27 — belonging to the elephant they had killed

in Gonarezhou National Park.

IV. The Wires Transmitted for the Purpose of Executing the Scheme

23. On or about the dates set forth below, for the purposes of executing such scheme

and artifice, HANNO VAN RENSBURG did transmit and cause to be transmitted by means of

wire communications in interstate and foreign commerce, writings, signs, signals, pictures and

sounds, as set forth below:

Count Approximate Date Description

ONE March 9, 2015 Wire Transfer of approximately $19,195 from Colorado-
based U.S. Bank account xxxxxxxxxxx6430 in the name of
COLORADO HUNTER to ABSA Bank Limited in South
Africa as partial payment for an elephant hunt
TWO April 20, 2015 Wire Transfer of approximately $20,000 from Colorado-
based U.S. Bank account xxxxxxxxxxx6430 in the name of
COLORADO HUNTER to ABSA Bank Limited in South
Africa as partial payment for an elephant hunt
THREE February 22, 2016 Email from VAN RENSBURG to, among others,
COLORADO HUNTER’s Colorado-based email relating to
an effort to obtain a false certification that COLORADO
HUNTER resided in South Africa.

All in violation of Title 18, United States Code, Sections 2 and 1343.

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COUNT 4

24. Paragraphs 15 through 22 of this Indictment are hereby re-alleged as if set out in

full and incorporated herein by reference.

25. Between in or about April 2015 and August 2016, both dates being approximate

and inclusive, in the State and District of Colorado and elsewhere, HANNO VAN RENSBURG,

did knowingly combine, conspire, confederate and agree with COLORADO HUNTER,

FACILITATOR, and with other persons known and unknown to the Grand Jury, to commit wire

fraud in violation of Title 18, United States Code, Section 1343.

I. Purpose of the Conspiracy

26. A purpose of the conspiracy was to deceive the government of Zimbabwe in order

to kill the largest bull elephant HANNO VAN RENSBURG, COLORADO HUNTER, and the

rest of their hunting party could find and then export that elephant outside of Zimbabwe.

II. Manner and Means of the Conspiracy

27. The conspiracy was furthered using the following manner and means:

a. VAN RENSBURG and COLORADO HUNTER paid bribes to Zimbabwe

game scouts so that those government officials would allow the illegal hunt and allow the dead

elephant’s ivory to be transported outside of the park;

b. VAN RENSBURG, COLORADO HUNTER, and FACILITATOR,

falsely represented on a Zimbabwe hunting permit that the African Elephant was killed outside

of Gonarezhou National Park;

c. VAN RENSBURG, COLORADO HUNTER, and FACILITATOR sought

to manufacture and submit to the Zimbabwe Parks and Wild Life Authority a letter, affidavit, or

document falsely stating that COLORADO HUNTER was a resident of South Africa.

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d. VAN RENSBURG, COLORADO HUNTER and FACILITATOR used

email servers located in the United States and elsewhere to communicate with one another about

efforts to export an elephant illegally killed in Gonarezhou National Park from Zimbabwe to

South Africa.

All in violation of Title 18, United States Code, Section 1349.

COUNT 5

28. Paragraphs 16 through 19 of this Indictment are hereby re-alleged as if set out in

full and incorporated herein by reference.

29. The Zimbabwean Parks and Wild Life Act made it unlawful, with certain

exceptions granted by the Zimbabwe Parks and Wild Life Authority, to hunt any wildlife in a

national park or to sell any animal or any part of an animal which has been hunted in or has died

in or has been removed from a national park. That same act designated a 505,300 hectare area

of the Chiredzi District of Zimbabwe as a national park called Gonarezhou National Park.

30. Between in or about April, 2015, and May, 2015, both dates being approximate

and inclusive, in the State and District of Colorado and elsewhere, the defendant, HANNO VAN

RENSBURG, did knowingly engage in conduct that involved the sale and the intent to sell

wildlife with a market value in excess of $350.00, that is, an African Elephant (Loxodonta

Africana) to COLORADO HUNTER and did knowingly sell that African Elephant in interstate

and foreign commerce knowing that the African Elephant was taken in violation of and in a

manner unlawful under the laws of Zimbabwe, specifically the Zimbabwe Parks and Wild Life

Act.

All in violation of Title 16, United States Code, Sections 3372(a)(2)(A) and

3373(d)(1)(B).

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COUNT 6

31. Paragraph 29 of this Indictment is hereby re-alleged as if set out in full and

incorporated herein by reference.

32. As part of his outfitting business, AUTHENTIC AFRICAN ADVENTURES,

HANNO VAN RENSBURG travelled to hunting conventions in the United States to market

African hunts to American hunters, including hunters in Colorado. Between February 2016 and

February 2017 HANNO VAN RENSBURG marketed and advertised himself to

UNDERCOVER HUNTER as an outfitter who would help his clients hunt and export large bull

African elephants through a variety of illegal methods and means, including (1) helping his

clients illegally obtain permits to hunt in and around Gonarezhou National Park, (2) working

with his clients to obtain false justifications to hunt the large elephants that frequent Gonarezhou

National Park, (3) illegally hunting elephants inside Gonarezhou National Park, (4) making false

statements to help clients obtain the permits necessary to hunt and transport elephant trophies,

and (5) paying bribes to appropriate Zimbabwean government officials to permit otherwise

illegal hunts. After advertising himself this way, using his successful hunt with COLORADO

HUNTER as an example, VAN RENSBURG attempted to sell UNDERCOVER HUNTER the

same illegal hunting experience.

I. HANNO VAN RENSBURG’s Marketing and Advertising of an Illegal

Hunt to UNDERCOVER HUNTER in February 2016.

33. Between approximately February 3, 2016 and February 6, 2016, HANNO VAN

RENSBURG operated a booth for AUTHENTIC AFRICAN ADVENTURES at a convention in

Las Vegas, Nevada. At the booth, VAN RENSBURG advertised that he was a professional

hunter from South Africa in the business of guiding hunters in their efforts to kill large African

elephants.

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34. UNDERCOVER HUNTER met with HANNO VAN RENSBURG and

COLORADO HUNTER at the booth for AUTHENTIC AFRICAN ADVENTURES on February

5, 2016. At that time, the United States Fish and Wildlife Service banned the import into the

United States of sport-hunted African Elephant trophies. VAN RENSBURG told

UNDERCOVER HUNTER that he could not guarantee that UNDERCOVER HUNTER would

be able to bring ivory back from Zimbabwe but suggested “anything is possible, you just have to

know how.” VAN RENSBURG then advertised the work he had done for COLORADO

HUNTER, telling UNDERCOVER HUNTER that COLORADO HUNTER had killed a large

elephant in Gonarezhou National Park and that he was trying to get the elephant ivory out of

Zimbabwe but “there are no guarantees.” VAN RENSBURG also marketed himself as

someone who would commit illegal acts for his clients, if necessary to secure a large elephant

trophy. As an example, when asked whether the Zimbabwe government would authorize the

killing of African Elephant inside Gonarezhou National Park, VAN RENSBURG told

UNDERCOVER HUNTER he had been able to “make it ok” and “justify” an incursion into

Gonarezhou National Park on “safety grounds.”

35. UNDERCOVER HUNTER met again with HANNO VAN RENSBURG at the

booth for Authentic African Adventures on February 6, 2016.

a. During the meeting VAN RENSBURG quoted a price of $50,000 for a 12-

day elephant hunt.

b. When UNDERCOVER HUNTER asked VAN RENSBURG about a hunt

inside Gonarezhou National Park, VAN RENSBURG stated “we shot that thing in the

Gonarezhou — that is not allowed” and “we shot it in the park. . . . We did a lot of things with

[COLORADO HUNTER] Go into the park, get the big elephant, come back, it’s not supposed

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to be like that.” Later, when UNDERCOVER HUNTER expressed disbelief about

“government guy” going along with the hunt, VAN RESNBURG responded “money talks.”

c. VAN RENSBURG told UNDERCOVER HUNTER that it would be a bad

idea to plan an illegal hunt from the start, but that he was willing to be flexible if the right

circumstances emerged during a hunt. VAN RENSBURG told UNDERCOVER HUNTER “I

don’t want to, I don’t want to do things like that . . . .It’s available. On the hunt things might

happen but you can’t tell, when I get to there I get a different scout I don’t know. I might get

another guy working there which I don’t know. So every time you go there, it’s different.

There’s not one guy may be the same but the rest is new guys. So you don’t know their ways,

you don’t know. Zimbabwe is fucked up. That’s what I’m telling you. There’s good

hunting, but the system, the system. And if you go in, we need to fly in, you know. Fly in.

When we’re done hunting you got to fly out. Get in a plane.”

d. Earlier in the conversation, VAN RENSBURG used his hunt with

COLORADO HUNTER as an example, telling UNDERCOVER HUNTER “the goal was to get

it on the ground. Go back. I didn’t even stop at the border. Clear guns. I didn’t. Pay

money. Whoom. I had enough.” He then told UNDERCOVER HUNTER “to get the

elephant in that park, there was a lot of, you know, need to sort out this guy, need to keep this

guy. You know, there’s a lot of things to do so, if it turns out bad, what happens? If it turns

out bad, I don’t want to be there anymore.”

II. HANNO VAN RENSBURG’s Continued Efforts to Sell

UNDERCOVER HUNTER an Illegal Hunt

36. After the convention in 2016, and just before another convention in 2017,

HANNO VAN RENSBURG continued his effort to sell UNDERCOVER HUNTER a hunt

similar to the one he had sold COLORADO HUNTER. On July 8, HANNO VAN

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RENSBURG sent a text to UNDERCOVER HUNTER in Colorado about a future hunt: “I will

set you up and go but fly in only!!! Will go to same place where [COLORADO HUNTER] and

120 pounder was kill! But no guarantee on any tusk come out of Zim! Hunt for picture!!! Zim

system failed. I will only be observer and body guard lol.”

37. After receiving the text from HANNO VAN RENSBURG, UNDERCOVER

HUNTER called VAN RENSBURG from Colorado on July 8, 2016, and spoke to him on the

telephone. During the call, VAN RENSBURG told UNDERCOVER HUNTER “last time I

paid $8,000 in 14 days in bribery to make everything happen. You know, to pay $8,000 out of

my pocket for — you know, it’s not worth it . . . I get a happy customer, but I take the loss.”

38. On January 6, 2017, HANNO VAN RENSBURG continued his text conversation

with UNDERCOVER HUNTER, telling UNDERCOVER HUNTER via text that he stays in the

United States during his “low season” between November and March and that “marketing season

is dec jan feb march!”

39. On January 14, 2017 UNDERCOVER HUNTER received in Colorado a text from

HANNO VAN RENSBURG: “I send all the emails from them! Big 100 pounder plus charter

in and out that area its more ore [sic] less 54000 plus charter and some money add $9000 to be

sure! Get to easy $63000.” That same day, UNDERCOVER HUNTER received from VAN

RENSBURG an email chain comprising correspondence between VAN RENSBURG and the

Zimbabwean hunter who had facilitated COLORADO HUNTER and VAN RENSBURG’s 2015

hunt inside Gonarezhou National Park. The email included pricing information for a hunt. In

the email forwarding the chain to UNDERCOVER HUNTER, VAN RENSBURG wrote “Now

you decide.”

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40. That same day, January 14, 2017, UNDERCOVER HUNTER and HANNO VAN

RENSBURG continued discussing the possibility of an elephant hunt and the status of

COLORADO HUNTER’s effort to get the elephant out of Zimbabwe via text message:

UNDERCOVER HUNTER: “Did you guys film [COLORADO HUNTER’s] hunt?”

VAN RENSBURG: “No it was night! And when we go in there we did no

camera was allowed. [UNDERCOVER HUNTER] that
hunt was one of my night mares! Plenty bribes to get that
elephunt [sic].”

UNDERCOVER HUNTER: “He said he finally got it out of Zim.”

VAN RENSBURG: “I hate when things go wrong and need to pay for that [sic]
I paid already. Yes but no easy. Many dollars later.”

III. HANNO VAN RENSBURG’S Attempt to Sell UNDERCOVER

HUNTER an Illegal Hunt in February 2017

41. UNDERCOVER HUNTER met with HANNO VAN RENSBURG at a

convention in Las Vegas on February 1, 2017.

a. During the meeting, VAN RESNBURG said there were approximately 8

or 9 elephant tags available. However, VAN RENSBURG stated “But you know about

Zimbabwe, how it works. If they need another tag, they get another tag. You know, that’s the

negative part of it. The system is so corrupt. If they need to get it, they will get it. If the

client pays the money they will find another tag. I am straightforward with you. Corruption is

the rule in Africa.” VAN RENSBURG quoted a price of $65,000 for an elephant hunt in

Zimbabwe. He also suggested that UNDERCOVER HUNTER have about $9,000 for “extras.”

“Some of that money we can use in camp to make things straight if we need to, which with

[COLORADO HUNTER] I had to get it out of my pocket. I tell him straight it was, you know I

had to do some things to sort it out.” VAN RENSBURG then complained that because the

price of sorting things out was not planned in advance “I pay, it doesn’t work for me like that. I

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put it in a quote. I show you. . . . So I put it in there now. How we spend that, you will see

it, and I say something happen . . . . We don’t use it, give back to you.”

b. UNDERCOVER HUNTER showed VAN RENSBURG a photo of

COLORADO HUNTER posing with the elephant killed in Gonarezhou National Park in 2015.

VAN RENSBURG then identified other men in the photograph as Zimbabwean game scouts.

“That was in the park . . . . Everyone was part of making it happen. But they was good. That

guide was good with us, you know. We had no problem and I could have, probably give them

less money, but I said, you know ‘everything is good.’ And they said, they told me amount that is

good for everyone split and everyone is good.”

c. VAN RENSBURG then again provided an example to UNDERCOVER

HUNTER of the type of service he was willing to provide clients. VAN RENSBURG told

UNDERCOVER HUNTER that COLORADO HUNTER actually shot three elephants in 2015:

“the thing is, you know, and to make all this because you got a client you want to send back

happy with tusks, get a picture, that’s the most important thing. That’s why . . . I don’t do

things like that. . . . First one was at night — not allowed.” VAN RENSBURG then

explained that if an animal was wounded it was considered “hunted” and that you have to pay for

it even if you don’t find it. “So that’s what the eight thousand dollars gets you, so they forget

about the first one.” VAN RENSBURG said that a second elephant, a smaller one, was shot by

a professional hunter in their party, but that VAN RENSBURG thought it was the wrong

elephant. The third elephant, the one that COLORADO HUNTER shot and killed in the park,

was a wounded one that was tracked for about ten miles.

d. While VAN RENSBURG was speaking to UNDERCOVER HUNTER at

the booth, VAN RENSBURG sent an email to the Zimbabwean hunter who could sponsor their

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hunt in the same concession area COLORADO HUNTER and VAN RENSBURG had visited as

part of the 2015 hunt inside Gonarezhou National Park. VAN RENSBURG also attempted to

sell UNDERCOVER HUNTER the hunt, telling UNDERCOVER HUNTER that

UNDERCOVER HUNTER could transfer money to a bank account in the United States

controlled by VAN RENSBURG.

42. Between in or about February 2016 and February 2017, in the State and District

of Colorado and elsewhere, the defendant, HANNO VAN RENSBURG, did knowingly engage

in conduct that involved the offer to sell and the intent to sell wildlife with a market value in

excess of $350.00, that is, an African Elephant (Loxodonta Africana) to UNDERCOVER

HUNTER and did knowingly attempt to sell, receive, and acquire that African Elephant in

interstate and foreign commerce in violation of and in a manner unlawful under the laws of

Zimbabwe, specifically the Zimbabwe Parks and Wild Life Act.

All in violation of Title 16, United States Code, Sections 3372(a)(2)(A), 3372(a)(4), and

3373(d)(1)(B).

COUNT 7

43. Paragraphs 16 through 22, 29, 34-37, 40, and 41, and all relevant sub-paragraphs,

are incorporated here by reference as if fully set forth within this Count.

44. Between in or about April 2015 and August 2016, in the State and District of

Colorado and elsewhere, the defendant, HANNO VAN RENSBURG, knowingly violated and

did aid, abet, counsel, command, induce and procure the violation of, a Fish and Wildlife Service

Regulation, to wit the regulation making it unlawful to deliver, carry, transport, or ship in foreign

commerce a CITES-protected African Elephant (Loxodonta Africana) taken in violation of the

Zimbabwe Parks and Wild Life Act, in the course of commercial activity.

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All in violation of Title 18, Section 2; Title 16, United States Code, Sections

1538(a)(1)(G) and 1540(b)(1); Title 50, Code of Federal Regulations, Sections 17.11, 17.21(e),

17.31(a), and 17.40(e)(6)(ii).

A TRUE BILL:

Ink signature on file in Clerk’s Office

FOREPERSON

ROBERT C. TROYER
United States Attorney

By: s/Bryan David Fields

BRYAN DAVID FIELDS
SUNEETA HAZRA
Assistant U.S. Attorneys
U.S. Attorney’s Office
1801 California Street, Suite 1600
Denver, CO 80202
Telephone: (303) 454-0100
Fax: (303) 454-0409
e-mail: Bryan.Fields3@usdoj.gov
Attorney for the Government

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Case 1:18-cr-00238-PAB Document 1-1 Filed 05/17/18 USDC Colorado Page 1 of 2

DEFENDANT: Hanno Van Rensburg

YOB: 1974

COMPLAINT ______ Yes ___X____ No

FILED?
If Yes, MAGISTRATE CASE NUMBER_____________

HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? ________ Yes _____X__ No

If No, a new warrant is required

OFFENSE(S): COUNTS ONE - THREE: Wire Fraud (18 U.S.C. §§ 1343, 2)

COUNT FOUR: Conspiracy, (18 U.S.C. § 1349)

COUNT FIVE: Lacey Act Violation (16 U.S.C. §§ 3372(a)(2)(A) and

3373(d)(1)(B)

COUNT SIX: Attempted Lacey Action Violation (16 U.S.C. §§

3372(a)(2)(A); 3372(a)(4); 3372(d)(1)(B))

COUNT SEVEN: Endangered Species Act Violation (16 U.S.C. §§

1538(a)(1)(G) and 1540(b)(1); 50 C.F.R, §§ 17.11, 17.21(e), 17.31(a), and
17.40(e)(6)(ii); 18 U.S.C § 2)

LOCATION OF Mesa County, Colorado and elsewhere

OFFENSE:

PENALTY: COUNTS ONE-FOUR: NMT 20 years’ imprisonment; NMT fine greater

than or equal to 2X the loss, or $250,000, whichever is greater (or both a
fine and imprisonment); NMT 3 years’ supervised release; $100 Special
Assessment, Restitution.

COUNTS FIVE-SIX: NMT 5 years’ imprisonment; NMT fine greater than

or equal to 2X the loss, or $250,000, whichever is greater (or both a fine
and imprisonment); NMT 3 years’ supervised release; $100 Special
Assessment; Restitution.

COUNT SEVEN: NMT 6 months’ imprisonment, NMT $25,000 fine, or

both, $10 Special Assessment

AGENT: FWS-OLE Special Agent Anne-Marie Sharkey

AUTHORIZED Bryan David Fields

BY: Assistant U.S. Attorney

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Case 1:18-cr-00238-PAB Document 1-1 Filed 05/17/18 USDC Colorado Page 2 of 2

ESTIMATED TIME OF TRIAL:

X five days or less ____ over five days ____ other

THE GOVERNMENT

will seek detention in this case based on 18 U.S.C. § 3142(f)(1)

__X____ will not seek detention

The statutory presumption of detention is applicable to this defendant.

OCDETF CASE: Yes X No