Illicit Money Transmitters Admit Criminal Scheme to Funnel Money to Nevada Casino
2023-10-27 · Press release
Summary: SAN DIEGO – Two Mexican nationals and their unlicensed money transmitting business admitted in federal court today that they illegally helped foreign gamblers move money stealthily through the U.S. financial system to avoid scrutiny by U.S. and foreign law enforcement and regulators.
NEWS RELEASE SUMMARY – October 27, 2023
SAN DIEGO – Two Mexican nationals and their unlicensed money transmitting business admitted in federal court today that they illegally helped foreign gamblers move money stealthily through the U.S. financial system to avoid scrutiny by U.S. and foreign law enforcement and regulators.
Defendants Francisco Alberto Garza-Vargas and Ricardo Najera-Almaguer, both of San Pedro Garza Garcia, Mexico, and Carma de Monterrey SA de CV, a Mexican corporation headquartered in Monterrey, Mexico, admitted they conspired to operate an unlicensed money transmitting business on behalf of foreign patrons of the casino industry.
Garza-Vargas was previously a registered agent with the Nevada Gaming Commission. Casinos typically contract with such agents to be a liaison between casinos and high-rolling guests. These agents bring players into a particular casino; and in return, they are compensated with commission by that casino.
According to court documents, the defendants’ unlicensed money transmitting enterprise conducted more than 115 illegal transfers with bank accounts controlled by the casino industry in the aggregate amount of approximately $8,129,664.
These cases bring to 15 the total number of defendants who have admitted wrongdoing in this investigation into money laundering, unlicensed money transmitting, and other crimes, with associated criminal penalties of over $7.5 million.
During today’s hearing, U.S. District Judge Dana M. Sabraw accepted Garza-Vargas’ and Najera-Almaguer’s deferred prosecution agreements and the corporation’s guilty plea and ordered the defendants to pay criminal fines and other financial penalties totaling $3,198,397.
According to court documents, the defendants conducted financial transactions for casino patrons located abroad who sought to gamble in the United States. To have funds available for that purpose in the United States, the defendants transferred the patron’s funds through a series of bank accounts controlled by the corporation defendant and others into casino-controlled bank accounts. The circuitous transfers helped patrons evade laws and regulations designed to prevent money laundering.
As a result of not registering their money transmitting business, not maintaining an anti-money laundering program, and not filing required suspicious activity reports or currency transaction reports, the defendants were able to conceal the sources of funds. This conduct obscured the nature of the transactions from other United States-based financial institutions and inhibited the ability of law enforcement and other authorities to investigate.
Today’s proceedings follow a similar resolution as that of defendant Juan Carlos Palermo on April 20, 2022, who in a related case admitted to money laundering in the promotion of his own unlicensed money transmitting business. Since October 2012, while acting as an agent for one casino, defendant Palermo operated multiple unlicensed businesses in the United States and abroad that conducted more than 200 transfers with bank accounts controlled by multiple casino entities, over $17.7 million, on behalf of at least 50 casino gambling patrons.
Between approximately 2012 and 2020, defendant Palermo and his unlicensed money transmitting business transacted with clients, and related financial accounts, in at least 15 countries, including countries that the United States Department of State has identified as “Major Money Laundering Countries” of “primary concern” like Mexico, Argentina, Cayman Islands, Switzerland, United Arab Emirates, and Hong Kong. The Palermo money transmitting business’s use of these bank accounts and other financial services allowed clients to conduct international monetary transfers through underground financial networks engaged in transferring funds, exchanging currency, and other money transmitting and remitting services, while circumventing laws and regulations regarding monetary transfer and reporting in the U.S. and elsewhere.
This case is being prosecuted by Assistant U.S. Attorneys Carl F. Brooker IV, Christopher Beeler, and Mark W. Pletcher and investigated by Homeland Security Investigations and the IRS Las Vegas Financial Crimes Task Force.
DEFENDANTS
Francisco Alberto Garza-Vargas Age: 59 San Pedro Garza Garcia, MX
(Case Number 23-CR-0219-DMS)
Ricardo Najera-Almaguer Age: 68 San Pedro Garza Garcia, MX
(Case Number 23-CR-0219-DMS)
Carma de Monterrey S.A. de CV Monterrey, MX
(Case Number 22-CR-0219-DMS)
Juan Carlos Palermo Age: 64 Buenos Aires, Argentina
(Case Number 22-CR-0859-DMS)
SUMMARY OF CHARGES
Conspiracy to Operate an Unlicensed Money Transmitting Business – Title 18, U.S.C., Section 371
Maximum penalty: Five years in prison and $250,000 fine
AGENCIES
Homeland Security Investigations
IRS-Criminal Investigations, Las Vegas Financial Crimes Task Force
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- https://www.justice.gov/usao-sdca/pr/illicit-money-transmitters-admit-criminal-scheme-funnel-money-nevada-casino
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| participant_id | name | role | title | organization | location | age | nationality | status |
|---|---|---|---|---|---|---|---|---|
| 1421 | Francisco Alberto Garza-Vargas | defendant | San Pedro Garza Garcia, Mexico | 59 | Mexican | deferred prosecution agreement | ||
| 1422 | Ricardo Najera-Almaguer | defendant | San Pedro Garza Garcia, Mexico | 68 | Mexican | deferred prosecution agreement | ||
| 1423 | Carma de Monterrey S.A. de CV | defendant | Carma de Monterrey S.A. de CV | Monterrey, Mexico | Mexican | guilty plea | ||
| 1424 | Juan Carlos Palermo | defendant | Buenos Aires, Argentina | 64 | Argentinian | admitted wrongdoing | ||
| 1425 | Carl F. Brooker IV | prosecutor | Assistant U.S. Attorney | U.S. Attorney's Office | San Diego, California | |||
| 1426 | Christopher Beeler | prosecutor | Assistant U.S. Attorney | U.S. Attorney's Office | San Diego, California | |||
| 1427 | Mark W. Pletcher | prosecutor | Assistant U.S. Attorney | U.S. Attorney's Office | San Diego, California | |||
| 1428 | Dana M. Sabraw | judge | U.S. District Judge | U.S. District Court | San Diego, California |
| agency_id | agency_name | abbreviation | role | office_location | agents_mentioned | contribution |
|---|---|---|---|---|---|---|
| 894 | Homeland Security Investigations | investigation | Investigated the case involving illegal money transfers and money laundering. | |||
| 895 | IRS Las Vegas Financial Crimes Task Force | investigation | Las Vegas | Investigated the case as part of the IRS Criminal Investigations unit. |
| charge_id | charge_description | statute | severity | max_penalty | fine_amount | defendant | status | participant_id | cl_docket_id | count_num | is_1960 | verified_1960 | source | updated_at |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 714 | Conspiracy to Operate an Unlicensed Money Transmitting Business | 18 U.S.C. § 371 | Five years in prison | $250,000 | Francisco Alberto Garza-Vargas | deferred prosecution agreements | 1 | enrichment | 2026-09-16T19:45:55+00:00 | |||||
| 715 | Conspiracy to Operate an Unlicensed Money Transmitting Business | 18 U.S.C. § 371 | Five years in prison | $250,000 | Ricardo Najera-Almaguer | deferred prosecution agreements | 1 | enrichment | 2026-09-16T19:45:55+00:00 | |||||
| 716 | Conspiracy to Operate an Unlicensed Money Transmitting Business | 18 U.S.C. § 371 | Five years in prison | $250,000 | Carma de Monterrey S.A. de CV | guilty plea | 1 | enrichment | 2026-09-16T19:45:56+00:00 | |||||
| 2655 | operate an unlicensed money transmitting business on behalf of foreign patrons of the casino industry | 1 | press | 2026-09-16T19:45:55+00:00 | ||||||||||
| 2656 | Operate an Unlicensed Money Transmitting Business – Title 18, U | 1 | press | 2026-09-16T19:45:55+00:00 | ||||||||||
| 2657 | unlicensed money transmitting business admitted in federal court today that th | 1 | press | 2026-09-16T19:45:55+00:00 | ||||||||||
| 2658 | unlicensed money transmitting business on behalf of foreign patrons of the cas | 1 | press | 2026-09-16T19:45:55+00:00 | ||||||||||
| 2659 | unlicensed money transmitting business | 1 | press | 2026-09-16T19:45:55+00:00 | ||||||||||
| 2660 | unlicensed money transmitting business transacted with clients, and related fi | 1 | press | 2026-09-16T19:45:55+00:00 | ||||||||||
| 2661 | Unlicensed Money Transmitting Business – Title 18, U | 1 | press | 2026-09-16T19:45:55+00:00 |
| fin_id | action_type | amount | currency | description | asset_type | defendant | status |
|---|---|---|---|---|---|---|---|
| 211 | criminal fines | $3,198,397 | USD | criminal fines and other financial penalties totaling $3,198,397 | cash | Francisco Alberto Garza-Vargas, Ricardo Najera-Almaguer, Carma de Monterrey S.A. de CV | ordered |
| victim_id | victim_type | description | number_affected | loss_amount | geographic_scope | vulnerability_factors | impact_description |
|---|---|---|---|---|---|---|---|
| 153 | government | U.S. and foreign law enforcement and regulators | U.S. and multiple countries including Mexico, Argentina, Cayman Islands, Switzerland, United Arab Emirates, and Hong Kong | Inhibited ability to investigate due to concealed transaction sources | |||
| 154 | financial institution | U.S.-based financial institutions | United States | Obstructed detection of transaction sources and nature through obscured financial trails |
| quote_id | quote_text | speaker_name | speaker_title | speaker_organization | quote_type | context | significance |
|---|---|---|---|---|---|---|---|
| 265 |
| theme_id | theme_name | description | significance | related_statutes | geographic_scope | temporal_aspects | stakeholders |
|---|---|---|---|---|---|---|---|
| 814 | Unlicensed Money Transmitting | Defendants operated an unlicensed money transmitting business to move funds for foreign gamblers through U.S. financial systems. | Enabled illegal movement of funds without regulatory oversight, evading detection by authorities. | 18 U.S.C. § 371 | International | 2012–2020 | Defendants, casinos, financial institutions, law enforcement |
| 815 | Money Laundering | Transfers were structured to obscure the source of funds and evade anti-money laundering laws. | Undermined financial transparency and regulatory frameworks designed to combat illicit financial activity. | International | Ongoing over years | Defendants, financial institutions, regulators | |
| 816 | Evasion of Regulatory Compliance | Defendants failed to register their business, maintain an AML program, or file required reports. | Allowed concealment of illicit transactions and hindered law enforcement investigations. | International | 2012–2020 | Defendants, financial regulators, law enforcement | |
| 817 | International Financial Transactions | Transfers involved multiple countries, including those designated as major money laundering hubs. | Enabled cross-border evasion of financial regulations and law enforcement scrutiny. | International | Ongoing over years | International financial networks, law enforcement agencies | |
| 818 | Casino Industry Complicity | Casinos collaborated with unlicensed agents to bring high-rolling gamblers and process illicit funds. | Facilitated the flow of untraceable gambling proceeds through legitimate financial channels. | National | Ongoing | Casinos, gaming agents, gamblers | |
| 819 | Financial Penalties and Legal Outcomes | Defendants faced criminal fines, deferred prosecution agreements, and restitution orders. | Serves as a deterrent and imposes financial consequences for violating financial regulations. | National | 2023 | U.S. courts, defendants, regulatory agencies | |
| 820 | Underground Financial Networks | Defendants used informal networks to transfer funds outside legal financial systems. | Allowed circumvention of reporting requirements and regulatory oversight. | International | Ongoing over years | Defendants, underground financial operators | |
| 821 | High-Risk Countries | Transactions involved countries flagged by the U.S. as major money laundering jurisdictions. | Highlighted vulnerabilities in global financial systems due to lax regulations in certain regions. | International | Ongoing | U.S. State Department, international law enforcement | |
| 822 | Law Enforcement and Regulatory Agencies | Homeland Security Investigations and IRS task forces led the investigation. | Demonstrated collaboration between agencies to combat transnational financial crimes. | National/International | Current | Homeland Security Investigations, IRS, DOJ | |
| 823 | Deferred Prosecution Agreements | Used to resolve charges against Garza-Vargas and Najera-Almaguer without full prosecution. | Provided an alternative to trial contingent on compliance with court-ordered terms. | National | 2023 | U.S. courts, defendants |
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