Date: September 2, 2022 Contact: email@example.com The Office of the United States Attorney filed federal criminal complaints charging money service business employees Griselda Cancelada Liceaga, Veronica Mora, and Yoselin Perez Ramirez with conspiracy to commit money laundering and identity theft in connection with a scheme to facilitate wire transfers for drug traffickers sending drug proceeds to their sources of supply in Mexico. The owner of the money service business Rincon Musical—Felipe de Jesus Ornelas Mora—was charged with conspiracy to commit money laundering, in a separate complaint, for his participation in the scheme. The announcement was made by U.S. Attorney Stephanie M. Hinds, Internal Revenue Service-Criminal Investigation (IRS-CI) Special Agent in Charge Mark H. Pearson, and Drug Enforcement Administration (DEA) Acting Special Agent in Charge Bob P. Beris. The defendants were arrested Wednesday, August 31, 2022, and made their initial federal court appearances the following morning before U.S. Magistrate Judge Donna M. Ryu. According to the criminal complaints, Ornelas was the owner of Oakland-based money transmitter Rincon Musical where Liceaga, Mora, and Ramirez worked as cashiers. All the defendants are Oakland residents. Liceaga eventually opened her own money transmitter business—America Latina—in Oakland. When providing money transmitter services, the defendants were acting as local agents of corporate money service businesses that maintain policies and require training to ensure compliance with national anti-money laundering laws and regulations. The anti-money laundering corporate policies as well as federal laws and regulations require money service businesses to avoid allowing their services to be used to support money laundering. The complaint alleges the defendants completed annual trainings and were aware of the applicable laws and policies and, nevertheless, charged unrecorded transaction "fees" to narcotics traffickers for assisting the traffickers with laundering drug proceeds from the United States to Mexico. The complaints describe several methods allegedly used by the defendants to launder drug proceeds. For example, the defendants allegedly used identification cards and personal information of legitimate customers to complete wire transfers in names other than those of the drug dealers. In addition, the defendants allegedly structured large amounts of cash into smaller wire transfers to avoid arousing suspicion that the wire transfers were drug proceeds. The complaints describe how a former narcotics trafficker working under the supervision of law enforcement agents brought $20,000 in cash to Rincon Musical to have wired to people in Mexico. Two of the defendants split the money into multiple transactions of less than $3,000—amounts small enough to avoid being flagged for suspicious activity. The complaint also alleges that defendants did not ask customers to explain the origin of large amounts of cash they agreed to wire as the defendants had been trained to do and did not record the "extra" transaction fees that they charged for helping process suspicious transactions. All of this, the complaint alleges, defendants did to assist drug traffickers who sent wire transfers without using their true names, showing identification, or having their transactions scrutinized by the corporate money service businesses that provide wire transfer services. The criminal complaints detail the IRS and DEA investigation that led to the arrest and charging of the defendants. According to the complaints, law enforcement arrested two drug traffickers—one in December 2020 and the other around June 2021—both of whom admitted to sending drug proceeds to their drug suppliers in Mexico at Rincon Musical. The complaints describe the drug traffickers' statements, cell phone communications, and transaction receipts found on their phones to demonstrate how they allegedly used money transmitter services to pay drug suppliers in Mexico. In addition, the complaints describe multiple covert operations that investigators used to determine how the defendants were allegedly circumventing anti-money laundering rules and allegedly using the personal information of legitimate customers to satisfy identification requirements on large suspicious transactions. In sum, the criminal complaints charge Ornelas, Liceaga, Mora, and Ramirez with conspiracy to commit money laundering, in violation of 18 U.S.C. § 1956(h). Liceaga, Mora, and Ramirez also are charged with identity theft, in violation of 18 U.S.C. § 1028(a)(7). If convicted, defendants face a maximum statutory term of 20 years in prison and a $500,000 fine (or twice the gain resulting from the crime). However, any sentence after a 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. Defendants Ornelas, Liceaga, and Mora are next scheduled to appear on September 6, 2022, before Magistrate Judge Donna M. Ryu for arraignment, identification of counsel, and further status on conditions of release. Defendant Yoselin Perez Ramirez is scheduled to appear on September 2, 2022, before Magistrate Donna M. Ryu for initial appearance and identification of counsel. Assistant U.S. Attorney Daniel Pastor is prosecuting this case with assistance from Amanda Martinez and Andy Ding. This case is the result of an investigation by IRS-Criminal Investigations and the DEA with assistance from the Oakland Police Department. This prosecution is part of an Organized Crime Drug Enforcement Task Forces (OCDETF) investigation. OCDETF identifies, disrupts, and dismantles high-level drug traffickers, money launderers, gangs, and transnational criminal organizations that threaten the United States, by using a prosecutor-led, intelligence-driven, multi-agency approach that leverages the strengths of federal, state, and local law enforcement agencies against criminal networks.