2:17-cr-00506-RMG J
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Date Filed 11/01/17
2:17-cr-00506-CRI *S��LED*
Entry Number 28 Entry 1)1.Ufl'lber 6
Date Fiied 06/07/17
Page 1 of 21 Page 1 of 21
IN THE DISTRICT COURT OF THE UNITED STATES FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION Criminal NO:
UNITED STATES OF'AMERICA y,
2:17-cr-00506
I>LEl\.".A.GRE�NT . I>UR$.U:�T T.O FE.D . . R, CRIM... J?ROC,
FOUR SEASONS GENERAL MERCHANDISE, INC. Federa1 Emp1oyment ID#
l.3-. ..tc;;J_(l) .. <.Cl
I
[UNDER SEAL]
I
General Provisions This PLEA AGREEMENT is made this 2017,
between the United States
7th
of America,
day of _J"'"'t= 1n""'e"--�-" as
represented by
Acting-United States Attorney Beth Drake, Assistant United States Attorneys Matt Austin and Jim May; GENERAL MERCHANDISE, INC.,
the Defendant,
FOQ'R SEASONS
and the Defendant's attorneys,
local
counsel Matt Hubbell, as well as Ariel Neuman �nd Jean Nelson.
IN CONSIDERATION
of
the mutual
promises made herein,
·1 the
parties agree as follows: 1.
The Defendant agrees to waive Indictment and arraignment, a.nd plead_guilty to an Information charging aiding and abetting
3392272.1
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Entry Number 28
Date Filed 06/07/17
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Entry Number 6
.,,--·._
an unlicensed money transmitting business, Title 18, United States Code
Page 2 of 21
(U.S.C.),
Page 2 of 21
in violation 0£
§ 1960(b) (1) (B)
and
Title 18 United States Code, § 2. The Defendant also agrees to waive venue and plead guilty to the Information in the District of South, Carolina. In order to sustain its burdeh of proof, the Government is required to prove the following: Count 1 a.
The Defendant, aided and abetted;
b.
The
operation
of
an
unlicensed
money
transmitting
business; that is a business i.
That tr.ansmitted funds;
ii.
Without complying with the requirements of 31
·u.s.c.
§ 5330.
The penalty for this offense is: a fine of not more than the greater Qf $500,000 or twice the gross pecuniary gain from the of.fense, plus a special assessment of $400. 2.
The Defendant represents that Ariel A. Defendant,
has
been
Directors to enter
authorized
Defendant's
into this Agreement
Defendant.
3392272.1
by
-2-
Neuman,
counsel to Board
of
on behalf of the
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3.
Entry Number 28
Page 3 of 21
Entry Number 6 ,r""
Page 3 of 21
The Defendant understand_s and agrees that monetary penal ti.es [j,.e.,- special assessments, fines and otp.er payments·required urn;ler the sentence) iinposed by the Court are due immediately and sqbject to enforcement by the United States as civil j udgmerits, pµrsuant to 18 U. S . c;: • § 3 613 . A.
Special Assessment:
Pursuant to 18 U.S.C. -
§3013,
.
the Defendant must pay a �pecial assessment of $400 for the count of convicti.on named above.
This
special assessment must be paid at or ·before the time of the guilty plea he.a.ring. B.
Fines:· The Defendant understands that· the Court may impose a fine pursuant to 18 O.!LC,
§§ 3571 and
3572. The parties agree that any fines,
forfei.tures, a:nd special
assessment resulting_fromtbe Plea Agreement will be paid out of the ftmd$ already seized,
and that this Agreement also
resolves all related seizures.
Because those funds have been
seized by the Government, the Government will return the funds necessary to pay ariy fines and special assessment to Defendant before the entry of·a guilty plea pursuant to this Agreement.
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Entry Number 28
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Entry NJ1(Tlber 6
Page 4 of 21
Date Filed 06/07/17
4. Fac.tua1 Basis: The Defendant voluntarily accepts criminal responsibility for the offense to which it is pleading guilty, and agrees that the following joint factual statement is a true and accurate statement,
which provides a sufficient
basis for the Defendant's plea of guilty to Count One.
The·
De.fendant further agrees that had this matter proceeded to trial,
the following . facts would be established beyond a
reasonable doubt thro-µgh competent evidence and testimony: a. Beginning no later than September 2014, General Merchandise, merchandise California,
Inc.
wholesaler aided and
E'our Seasons
(''Four Seasons"), located
abetted
in
Los
a general Angeles,
the operations
of
an
unlicensed money transmitting business which was engaged in the
interstate
and international
transmission of
funds without. complying with the requirements of Title 31,
United States Code, · Section 5330.
committed this
The Defendant
conduct , by and through the . acts and
omissions of its agents and employees· who were acting
within the scope of their agency and employment and with the intent to benefit the Defendant.
Specifically, Four
Seasons sold merchandise to long-time customers that were located in Mexico and received and accepted as payment fox goods sold cash deposits into its account at Bank of America. 3392272.1
Four Seasons recklessly disregarded -4-
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Entry �,!,!!ll ber 6
Page 5 of 21 Page 5 of 21
the fact that · certain paymen t s did not come directly from the customers but instead were made by indiv:i<:iua1s· . associated bus.iness .
with
an
unl icens ed
money
t ransmitting
The payment s ¢onstitlited mopeys owecJ. for .r eal
goods s old by Four Seasons to real customers located in Mexico .
The goods included. typical ''dollc1.r store " type
merchandi se such . as puzzles ,
night
lights ,
ice cube
t rays , and crayons . b . The parti es agree that at lea s t $ 2 3 2 , 8 3 6 . 0 0 in cash was . depos i t ed by individuals working for or at the direction of the unlicens ed money transmitter during the course of the offense . c . The parties agree t�at this amount does not cons t i tute the ga in to Four S e a s ons from its parti cipation in thi s offense , as it i s l i kely tha t some or all of the . long time Mexican cu stomers would have purchased and pi;iid for ·. goods
· /
regardl ess
of
whe the r
Four
S easons
accepted
pc1.yment through the unli cens ed money transmitter ,
and
s ince thi s number does not take i nto account cos t s o f goods sold a n d other costs ass ociated w i th t he sa l es of the goods in quest ion . d.
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Entry Number 28 Entry [)lllmber 6
Date Filed 06/07/17
Page 6 of 21 Page 6 of 21
,. ,.
5.
The
DefE:l ndant
unders tanc;Is
that
the
ob l igations
or
the
Government within the Plea Agreement a re .expres s l y contingent upon the Defendant abiding py federa l and state crbninal l aws . In the event that the Defendant fa i ls to comply with any o f . the provis ions of this Agreement , the Government will have the
right ,
at
its
sole
election ,
to
voi d
all
of
it s
obl i gati ons under thi s Agre ement and the Defendant wi l l not have
any ri·ght · to
withdraw
offense ( s ) enume:ra ted herein .
3392272,1
its
plea
of
gui l ty
to
the
; i
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Entry Number 28
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Entry N umber 6 {
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Page 7 of 21 Page 7 of 21
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;
i!
' i I l t
7 . The Gove rnment ag rees that i f the Defendant complies with the
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the Distri ct pros ecut e
of
Unit ed
south
or
Entry Number 28
States
Carolina
pursue
e
not
Office . for the
further
crimina lly
criminal ,
further
Page 8 of 21
Entry N/ u m ber 6 ·••>)
Attorney' s
wi ll
Page 8 of 21
civil (
or
adi:ninistrat i ve for fei tu:r e actions r_e lated to the Defendan for violat ions
of federal l aw
ari s ing out of the Government ' s investigation, including the conduct giving rise to the instant - . Plea Agreement ,
including
the conduct described in the s tipulated f_a ctual bas i s 'and the alleged receipt of payments or cash from any "rnone:y broker , " drug
traffi cker,
or
other
person
affiliated
with
such
individual , �hether re ce i ved irito bank accounts or otherwise � and wil l dismiss any such· ·claims that have beeh filed against the Pefendant .
The Gov�rnment furthe r agree s. that i f the?
Defendant complies with the terms o f thi s Agreement,
agrees to
recommend
to
any
other
pro secution of Four Seasons
j uris dicti on
cons idering for matters
rel ated to the conduct now unde r investigat i on that there should be no furthe r cha rges . ·
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Entry Number 28
Date Filed 06/07/17
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Entry N u mbef 6
r,
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Entry Number 28
Page 10 of 21
Entry N_y.Q1 ber 6. . \
Page 10 of 21
The Defendant a grees t o b e pla ced on probation provided
tl;lat s upervision is t rans ferred to t.J.le Central Di':s trict o f Cali:fornia
where
Defendant
is
loca ted.
The
Defendan:t ' s
proba:�ion term will _be for 3 6 rnont);i.s , , including a 1 2 -month ramp-up period during
which
t:he
Company
wi ll . submit
to
Probat ion for it s approval a · compliance and ethics program relating to .handling of cash, s t ructuring , and unlawful money transmis sion .
Subj.e ct
to
the
approval
o f the supervis ing
probat ion of .f i cer , the D�fendant will. retain a qualified �md ind�ptmdent individual or firm in or around the Los Angeles a rea t o moni tor· the Gompany ' - s compliance efforts du.r ing the probati on term .
Dnring th e a ctive supervis ion portion of the
probati.o na.r y· t erm, · if the compliance monitor determines that ther·e has been rnat:;erial non-compliance ,
the s ame wil l ·be
rep<:>rt ed to th� s-µpervising probation officer ;
agree that i f Defendant
11 .
to perfonn any obl i gat ion under th;i. s Agreement , the Government , in its sole dis cretion, may wi thdraw from this agreement .
3392272.1
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Entry Nu mber 6 ,'
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Page 11 of 21
violated the terms of thi s Agreement wi ll ,be determined · by !
I
evidence . Merger and Other Provisions 12 .
The Uni ted S tates and the defendant agree , pursuant to
Rule 11 (c) ( 1 ) (C) o f the Federal Rules of Criminal Pro cedure , that
the appropri a te s entence in thi s case
is
a fine of
$ 32 5 , 0 0 0 , a probationary peri od of 36 months , and a for feiture of property �n the amount of $ i , 3 4 0 , 6 61 . 9 9 .
The Defendant
· understands tnat should tl)e Court , a fter cons ideration cif tne c i rcumstanc e s
surrounding
this
case.,
accept
thi s
Plea
Agreement that the Court will no t have . the dis cretion to vary from the te rms set forth in thi s Agreem.ent . 13 .
The De fendant and the Government stipulate and agree to
the following for purpose s o f ca l cul a t ing the Defendant ' s s entence pursuant to the United States Sentencing Conuni s s ion Gu i del ines :
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Enfry N u m ber 6 (',I
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a . Four Se.as ons wi ll agre e for purposes of s ettlement that it recklessly dis.rega rded unl icensed money transmi s s i ons t o t aling $ 2 3 2 , 8 3 6 . 0 0 in cash b . The
appropria t e penalty
in
thi s
case
is
a
fine
of
$ 3 2 5 1 0 0 0 and a 3 6-month term of probation as set forth herein .
In addi tion , Defendant agrees to the forfeiture
set forth herein . c . Guide line s Calculations : § 2 Sl . 3 ( a ) ( 2 )
Ba.se O:ffense Level
§ 2Bl . l ( F )
Unlicensed payments : $232, 8 3 6
6 10 16
.,
i l I l
i-
d . The parties agree that the Defendant' s culpability score shou.ld be
3 . under
§
8C2 . 5 .
This
,repres ents
a
base
cu1pabi lity s core of 5 under § _ 8 C2 . 5 ( a ) and a two-point downward adj us tment fo r cooperation and acceptance of r e spon sibi lity under § 8C2 . 5 ( g) ( 2 ) . § 8C2 . 4 ( d }
Base Fine
§ BC2 . 6
Max and Min Multipliers
$300, 000 0. 6 1.2 $180 , 00 0 - $ 3 60 , 0 0 0
e . The part ie s agree that the fi ne w i l l b e paid o n the date of
3392272.1
s ent encing
from
the
- 1 2-
moneys
that
the
Gove rnment
i
\
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Entry Number 28
Page 13 of 21
Entry Nu mber 6
Page 13 of 21
Date Filed 06/07 /17
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previous l y s e i zed from Four Sec1s ons ' bank accounts . A $pecial assessment of $ 4 00 pursuant to § 8El . 1 will a l s o b e paid from the sei z ed fund� . in
Because thes e funds are
the pos s e s s ion of the Government ,
the
Government
agrees to effectuate pa yment o.f the speci al as s e ssment a.nd f ine . No resti tuti o.n sha l l be ordered under § BBl . 1 . 14 .
With
regard
to
each
and
every asset
lis ted
in
the
Inf o rmat ion, the Defendant s t ipul a tes and agrees : a . Defendant . a grees to voluntarily surrende r , and not cont est the forfeiture of the $ 1 , 6 65, 6 61 . 9 9 tnat was .seized by the government ( l ess any moneys subt racted t o pay the fine and special as se$$men t ordered in thi s cas e ) . ,
and i n return ,
the Government w i l l relea s e
Defendant
from
civil
and
· a dminis trative c laims re latin9 to the conduct under i nves tigation ,
and not s e i z e or seek to . forfeit any
· other funds owned or ill; the pos s e s sion of De fendant The parties agree that $ 2 3 2 , 8 3 6 . 0 0 $ 1 , 6 6 5 , 6 61 . 99 represents documen.t ed paymenJ:s from September 2 0 1 4 through the Ban� of America account in June 2 0 1 5 . The remain ing $ 1 , 4 3 2 , 8 2 5 . 9 9 repres ent s cash and oth e r instruments depos ited into Defendant ' s ban k account s tha t 3392272.1
have
not
been -13-
documented
as
paid
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Entry Number 28
Page 14 of 21
Entry N u m ber 6
Page 14 of 21
,.,,. ,,......,
but whi ch De fendant a g rees to forfeit a s pa1;t pf the resolution of this matter . b . The De fendant a grees and consents to the for feiture of these a ssets purs uant to any federa l criminal 1 ci v3,. l j udi ci a l or adrttinistra ti ve forfei tu;re action . The
Defendant
const}tuti onal ,
also
hereby . a.grees
to
wa.i ve
ail
statutory and procedural challenges
in any :manner ( including di re ct appeal , habe.a s corpus , or any other. means ) to any forfeiture carri�d out in accordance with this Plea Agreement on any · grounds , including constitutes
that an
the
forfeiture
exces s ive
fi.Ile ,
described wa s
not
herein prope.r ly·
notic�d in the charging .inst rument , ad9ressed by the Court at the time of the gui lty plea,
announced at
s en-tencing, or i ncorporated into the j q.dgment . c.
That the Defendant ha s · or had a po s ses s ory
· interes t or· other l egal interest in ea ch item or property . d.
To assist the United Sta tes ip t.h e rec overy of
the subj e ct a s sets by taking whatever steps are neces sa ry or re·qu e s t ed by the Unit ed State.s t o pa s s clear title to the Uni ted S t a t es . e.
The Defendant wa ives all rights to no t i ce of
for£e iture of the $ 1 , 665 , 661 . . 9 9 that wa s s eized by 3392272,1
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Page 15 of 21 Page 15 of 21
Entry Nu m ber 6 --
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the government under Rule 32 . 2 and of any other action or proceeding regarding these assets . The Defendant
consents
a.nd
waives
all
ri.ghts
to
compliance by the. United State.s with any appliCable deadlines under 18 administrative
o. s .C.
claim
983 (a) .
§
f"iled by
the
Any related Defendant is .
hereby withdrawn. f.
Pursuant
to
Rule
32 . 2 ( b ) ( 4) ,
the
Defendant
agrees that the preliminary order of forfe iture wi ll sat i s fy the notice requ i rement and will be final as to the Defendant at . the time it is entere d . Th the event t h e forfeiture i s omitted from the j udgment, the Defendant agrees that the forfeiture order may be \ incorporated into the wri tten j udgment at any time pursuant to Rule 36. g.
The
Defendant
agrees
to
waive
any
double
j eopardy claims the Defendant may have as a result of
a forfeiture
proceeding-
against any
of
the
property as provided for by this Plea A.greement and a grees to waive
any claims that
the forfeiture
described herein constitutes an excessive fine : 15 .
In the event that the Defendant complies with all terms
of this Agreement
and the Court d eclines to impose this
sentence, the Defendant will. have the r i ght to withdraw its 3392272;1
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Entry N u m be r 6 ,/-·,,
Page 16 of 21 Page 1 6 of 21
. FRCRP l l {CJ ( 1) ( c } plea . If the Defendant does not c omply with all the t erms of this Agreement , the United States may s e e k the maximum s entence allowed by law and the Defendant will not be allowed to withdraw 'its plea . 16 .
Defendant agr e es t o waive i ts right to the issuance of
a Presentence Investiga tion Report pursuant to Fed . R . Crim . P . 3 2 , ' and the parties agr e e that the information contained in .this Agreement , the Statement of Facts, and the Information are sufficient to enable the �ourt to meaningfully exercise its sentencing authority under 1 8 Fed. R .
Crim.
P.
u.s.c.
32 ( c ) ( 1) (A) ( ii ) .
§ 3 5 5 3 , pursuant t o
Both parties agree· to
recommend th.at the Defendant ' s change of plea hearing and sentencing be held on the same day . 17 .
The Defendant represents to the court that it has met
with its c1 ttorneys on a suffi c i ent number of o ccas i ons and :tor a sufficient period of time to discuss the Defendant ' s case and rece iye advi c e ; that the Defendant has been truthful with its attorneys and rela t ed all information of which the Defendant is aware pertaining to the c ase ; that the Defendant and its attorneys have discussed p o s sible defens es , if any, to the charges in the Information including the existence of any exculpato ry or favorable evidence or witnesses, discussed the Defendant'' s right to a public trial by j ury or by the Court, the right to the assistance of counsel throughout th e 3392272.1 ,
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Entry N>1J�1 ber 6 (
Page 17 of 21 Page 17 of 21
·I
j
.
proceedings , the right to call witnesses in the Defendant' s behalf and compel thei. r attendance at trial by s ubpoena , the right
to
confront
and
cross -examine
t.he
government ' s
witne s ses ; a nd that the Defendant, with the advice of counsel , has weighed the relative benefits of a trial by j ury or by the· Court versus a plea of guilty pursuant to this Agreement, and has ente �ed this Agreement a s a matter of the Defendant' s free and voluntary choice, a nd not a s a result of pres sure or intimidation by any person . 18 .
The Defendant i s aware that 1 8 U . S . C .
§ 3742 and 2 8
U . S . C . § 225 5 afford every defendant certain rights t o contest a conviction and/ or sentence .
Acknowledging those rights ,
the Defendant, in exchange for the concess ions , made by the Government in this Plea Agreement , waives the right to contest either the conviction or the sentence in any direct appea l or other post-convict ion action, i ncluding any proceedings under . 28 u. s . c .
§ 2255 .
( This waiver does not apply to claims of
ineffective assistance of counsel .or prosecutorial mis conduct raised pursuant to 28 U'. S . C . § 2 2 5 5 . ) 19.
The
Defendant
waives
all
rights ,
whether
asserted
directly: or by a represent a t ive, to request or receive from any department or agency of the United States any records pertaining to the investigation or prosecution of this ca s e , inc'luding without l imitation any records that may b e sought 3392272.1
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Entry NRm ber 6
Date Filed 06/07/17
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Entry Number 28
.
Page 18 of 21 Page 18 of 21
under tbe Freedom 0 £ In formation Act , 5 U . S . C . § 552 , or the Priva cy Act . 0£ 1 9 7 4 , 5 U . S . C . § 5 52 a .
21 .
The·
parties
hereby
contains the entire
agree
agreement
that
this
Plea · Agreement
of the- parti e s ;
that this
Ag-reement supersedes .a-1 1 prior promi s e l;l , representa tions and statements 0£ the pa rties ; tha t thi s Agreement shal l not be binding on any party untiL the Defendant tenders a plea of gui.i ty to the court having juri sdiction over thi s matter ; that thi s Agreement �ay b e · modi fied onl y i n writing s i gned by all
parties ;
repres entati ons
a nd and
that
any
statement s ,
and
al l
whether
other made
promises , pri or
to ,
contemporaneous wi th or after thi s Agreement , are null and void .
Date
3392272. 1 /
FOUR SEASONS GENERAL MERCHANDISE , INC . DEFENDANT
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Entry Number 28
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Entry Nu mber 6 ,..---..,l
•
'
c I i :; / , J/ .' '.f_l_ { - -·· - ·
Da\:<;1
�--�� Att:mC1.iuS14'AN ·;..Jcv�A-1\i: nfl'<)RNBY FOR T�m DBFBNQAN
6/�n 5. . fr. ::-,ll-n �. . Date
Dato
BETH l)JU\l(E
ONl'I'ED STA�SS A!l'TORNEY
� -ASSISTANT UN ITED STA',l'll8 Nl'roRNJt1
- 19 3392272 . 1
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Entry Number 6
Page 20 of 21 Page 20 of 21
JI � ASSISTANTUNIDSTATES ATTORNEY
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Page 21 of 21 Page 21 of 21
U. S. DEPARTMENT OF JUSTICE Statement of Special Assessment Amount This statement.reflects your $pecial assessment only. There may be other penalties imposed at sentencing� This Special Assessment is due· and payable at the time of the execution of the :plea agreement.
ACCOUNT INFORMATION . CRIM. ACTION NO.: DEFENDANT'S . NA�;
FOUR SEASOJ;ifS·
PAY TIDS AMOUNT:.
$400 .00
..
2 : 16-cr-00 189-RMG
(date plea agreeme11t signed)
PA-YMENT DUE ON OR BEFORE:
MAKE CHECK OR MONEY OJ.IDER PAYABLE TO: CLERK, U.S. DISTRICT COURT · .p.A,YIYJENT SHOULD BE SENT TO: Clerk, IJ.S� District Court Hollings Judicial Center 85 Broad Street Charleston, SC 29401 OR HAND DELIVERED TO: Clerk's Office Hollings Judicial Center 85 Broad Street Charleston, SC 29401 (Mon. - Fri. 8:30 a.m.-4:30 p.m.) INCLUDE DEFF.,NDANT'S NAME ON CHECK OR MONEY ORDER (.Do Not setttl cash}
ENCLOSE THIS COUPON TO JNSURE PROPER and PROMPJ'APPLICATIONOFPAYMENT 339227:2.1
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