Date: March 9, 2021 Contact: firstname.lastname@example.org SAN FRANCISCO — Former San Francisco public official Sandra Zuniga, charged in an information filed yesterday with conspiracy to commit money laundering, agreed in a plea agreement filed today to plead guilty and to cooperate with federal investigators in the corruption investigation into San Francisco City Hall, announced Acting United States Attorney Stephanie M. Hinds, Internal Revenue Service–Criminal Investigation Acting Special Agent in Charge Michael Daniels, and Federal Bureau of Investigation Special Agent in Charge Craig D. Fair. "Today a top San Francisco City Hall public official agreed to plead guilty to charges in our political corruption investigation and will cooperate with the FBI against others involved," said Acting United States Attorney Stephanie M. Hinds. "This investigation continues, but the window of time for cooperation is closing. If you are involved in public corruption at any level, reach out to the FBI before the FBI reaches out to you. Early cooperation is always viewed favorably." "Sandra Zuniga thought she could circumvent the law," said IRS Criminal Investigation, Acting Special Agent in Charge Michael Daniels. "Through numerous financial transactions, over a period of almost ten years, she attempted to hide the true source of Mohammed Nuru's funds. No public official should be allowed to behave as if they are above the law." "The FBI is very interested in interviewing San Francisco city government employees and contractors who may have first-hand knowledge of this public corruption scandal," said FBI Special Agent in Charge Craig D. Fair. "We believe that there are still city employees and contractors who may have pertinent knowledge that would be crucial to the ongoing investigation. In her plea agreement, Sandra Zuniga has agreed to cooperate with the FBI. We encourage others who have knowledge of this to do the same." Today's developments follow the June 3, 2020, federal complaint that charged Zuniga of South San Francisco, with engaging in a money laundering conspiracy. That earlier complaint against Zuniga followed public corruption charges filed in January 2020 against Mohammed Nuru, then Director of San Francisco's Department of Public Works (DPW). The charges against Nuru allege he engaged in schemes to bribe a San Francisco Airport Commissioner and to accept bribes from those doing business with DPW and the City. Multiple individuals have been charged with bribing Nuru, and some have pled guilty and are cooperating with the government's investigation. The June 3, 2020, federal complaint against Zuniga alleged that she laundered the proceeds of Nuru's schemes from 2014 through January 2020. The Zuniga complaint details how she made all-cash deposits in amounts that exceeded her San Francisco government paychecks by tens of thousands of dollars. She is alleged to have deposited checks from associates of Nuru and followed those deposits with transactions that benefitted Nuru. For example, the complaint alleged Zuniga made monthly mortgage payments for years on Nuru's Colusa County vacation home, almost always after depositing approximately $1,000 in cash into her own checking account and then writing a check for $1,000 to pay Nuru's monthly mortgage bill. The complaint also details a September 2018 set of transactions in which Zuniga received a $5,000 check from a contractor doing business with DPW and the City of San Francisco, deposited that check, executed a series of transactions with those funds through different banks, and then paid a $2,400 construction bill on Nuru's vacation home by writing a $2,500 check to herself, depositing it into another bank account, and sending a check from that account to the construction contractor to pay Nuru's bill. In another example, on one day in May 2014 Zuniga made two cash deposits into her account totaling $5,600, then four days later wrote a $3,800 check to Nuru and the next day paid $1,000 towards Nuru's mortgage bill. Further, the June 2020 complaint against Zuniga describes how she traveled in the fall of 2018 with Nuru on a lavish two-week trip to South America, with business class flights and Ritz-Carlton accommodations, all subsidized or paid entirely by a contractor doing business with the City. Yesterday's filed information charges Zuniga with engaging in the money laundering conspiracy with Nuru by conducting financial transactions with the proceeds of the crime of fraud, specifically wire fraud, and with the intent to conceal the nature and source of those funds, all while knowing the funds were derived from illegal activity. Zuniga has signed a plea agreement filed with the court today admitting the money laundering crime and expressing her intention to plead guilty to the crime. In her plea agreement, Zuniga agrees to cooperate with federal investigators in the ongoing federal investigation. Zuniga's admission of her own criminal conduct in her signed plea agreement, and a description of its circumstances and the people involved, has been submitted to the court in a separate "Exhibit A" to the plea agreement. Exhibit A is filed under seal with the court and not available at this time for viewing. While the Exhibit A description is not public, yesterday's publicly filed information does reveal further details. The money laundering conspiracy charged in today's information is alleged now to have begun years earlier than the date alleged in the original June 2020 complaint against Zuniga. While that complaint alleged the conspiracy began in March 2014, yesterday's information alleges the money laundering conspiracy began on "an unknown date, but at least as early as 2010" and continued into January 2020. Further, today's information alleges Zuniga conspired "with Mohammed Nuru and with other persons known" to the United States Attorney's Office in conducting and attempting to conduct the financial transactions to launder the proceeds of wire fraud. Zuniga is scheduled to be arraigned tomorrow, Wednesday, March 10, on the information before the Honorable Sallie Kim, United States Magistrate Judge. Zuniga is tentatively scheduled to make her initial appearance before the Honorable William H. Orrick, United States District Judge, in San Francisco on March 18, 2021. Zuniga remains out of custody on bond. Zuniga is charged with one count of conspiracy to launder money, in violation of 18 U.S.C. § 1956(h). The charge carries a maximum statutory penalty of 20 years in prison, a fine of $500,000 or twice the value of the property involved in the transactions, or both. However, any sentence following conviction would be imposed by the court only after consideration of the U.S. Sentencing Guidelines and the federal statute governing the imposition of a sentence, 18 U.S.C. § 3553. An information merely alleges that a crime has been committed, and all defendants are presumed innocent until proven guilty beyond a reasonable doubt. The prosecution is being handled by the Office of the U.S. Attorney, Northern District of California's new Corporate Fraud Strike Force and is the result of an investigation by the IRS-CI and FBI.