Operator of Underground, International Financial Institution Pleads Guilty to Operating Unlicensed Money Transmitting Business
2020-10-08 · Press release
For Further Information, Contact:
Assistant U.S. Attorneys Daniel C. Silva (619) 546-9713 and Mark W. Pletcher (619) 546-9714
SAN DIEGO – Liang Zhou pleaded guilty in federal court today to operating an unlicensed money transmitting business. His guilty plea is the third in this ongoing investigation targeting operators of unlawful underground financial institutions that transfer money between the United States and China, thereby circumventing domestic and foreign laws regarding monetary transfers and reporting, including United States anti-money laundering scrutiny and Chinese capital flight controls.
As part of his agreement to plead guilty, Zhou agreed to forfeit $446,330 to the United States as property involved in the operation of his unlicensed money transmitting business.
As admitted in the plea agreement entered today before U.S. Magistrate Judge Karen S. Crawford, Zhou sold hard currency in U.S. dollars that he collected from various, and occasionally unknown, third parties. His customers were typically individuals with bank accounts in China who could not readily access cash in the United States due to capital controls that cap the amount of Chinese yuan that an individual can convert to foreign currency. Often these customers needed the money to gamble at the casinos in Las Vegas. Upon receiving U.S. dollars, the customers would transfer from a Chinese bank account an equivalent value in yuan, over their mobile phones in the United States, to a separate bank account in China designated by Zhou.
"Individuals and organizations operating outside the conventional financial system represent a clear and present danger to the international banking system and the ability of law enforcement to detect and confront the criminal activity," said U.S. Attorney Robert S. Brewer. He commended prosecutors Daniel Silva and Mark Pletcher, as well as federal agents from Homeland Security Investigations, IRS Criminal Investigation Las Vegas Financial Crimes Task Force and the Drug Enforcement Administration for their excellent work on this case.
Sentencing is scheduled for January 8, 2021 before U.S. District Court Judge Dana Sabraw.
DEFENDANTS Case Numbers 20-CR-3084
Liang Zhou Las Vegas, NV Age: 37
SUMMARY OF CHARGES*
Operation of Unlicensed Money Transmitting Business – Title 18, U.S.C., Section 1960
Maximum penalty: Five years in prison, forfeiture, and $250,000 fine
AGENCIES
Homeland Security Investigations
IRS Criminal Investigation Las Vegas Financial Crimes Task Force
Drug Enforcement Administration
*The charges and allegations contained in an indictment or information are merely accusations, and the defendants are considered innocent unless and until proven guilty.
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- https://www.justice.gov/usao-sdca/pr/operator-underground-international-financial-institution-pleads-guilty-operating
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| participant_id | name | role | title | organization | location | age | nationality | status |
|---|---|---|---|---|---|---|---|---|
| 2017 | Liang Zhou | defendant | Las Vegas, NV | 37 | pleaded guilty | |||
| 2018 | Daniel C. Silva | prosecutor | Assistant U.S. Attorney | U.S. Attorney's Office | San Diego | |||
| 2019 | Mark W. Pletcher | prosecutor | Assistant U.S. Attorney | U.S. Attorney's Office | San Diego | |||
| 2020 | Karen S. Crawford | judge | U.S. Magistrate Judge | U.S. District Court | San Diego | |||
| 2021 | Robert S. Brewer | prosecutor | U.S. Attorney | U.S. Attorney's Office | San Diego | |||
| 2022 | Dana Sabraw | judge | U.S. District Court Judge | U.S. District Court | San Diego |
| agency_id | agency_name | abbreviation | role | office_location | agents_mentioned | contribution |
|---|---|---|---|---|---|---|
| 1251 | Homeland Security Investigations | HSI | investigation | Contributed to the investigation as part of the case work | ||
| 1252 | IRS Criminal Investigation Las Vegas Financial Crimes Task Force | investigation | Las Vegas | Contributed to the investigation as part of the case work | ||
| 1253 | Drug Enforcement Administration | DEA | investigation | Contributed to the investigation as part of the case work |
| 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 |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 1055 | Operation of Unlicensed Money Transmitting Business | 18 U.S.C. § 1960 | Five years in prison | $250,000 | Liang Zhou | pleaded guilty | 1 | enrichment | 2026-09-16T19:45:58+00:00 | |||||
| 2971 | operating an unlicensed money transmitting business | 1 | press | 2026-09-16T19:45:58+00:00 | ||||||||||
| 2972 | unlicensed money transmitting business | 1 | press | 2026-09-16T19:45:58+00:00 | ||||||||||
| 2973 | Unlicensed Money Transmitting Business – Title 18, U | 1 | press | 2026-09-16T19:45:58+00:00 |
| fin_id | action_type | amount | currency | description | asset_type | defendant | status |
|---|---|---|---|---|---|---|---|
| 399 | forfeiture | $446,330 | USD | property involved in the operation of his unlicensed money transmitting business | cash | Liang Zhou | ordered |
| 400 | fine | $250,000 | USD | maximum penalty for operating unlicensed money transmitting business | monetary penalty | Liang Zhou | pending |
| victim_id | victim_type | description | number_affected | loss_amount | geographic_scope | vulnerability_factors | impact_description |
|---|---|---|---|---|---|---|---|
| 279 | individual | individuals with bank accounts in China who could not readily access cash in the United States due to capital controls | United States and China | capital controls limiting access to foreign currency | Used Zhou's service to bypass Chinese capital flight controls to obtain U.S. dollars for gambling in Las Vegas |
| quote_id | quote_text | speaker_name | speaker_title | speaker_organization | quote_type | context | significance |
|---|---|---|---|---|---|---|---|
| 1336 | Individuals and organizations operating outside the conventional financial system represent a clear and present danger to the international banking system and the ability of law enforcement to detect and confront the criminal activity | Robert S. Brewer | U.S. Attorney | U.S. Department of Justice | statement | Commenting on the dangers posed by unlicensed money transmitting businesses | Highlights the threat to the international banking system and law enforcement's ability to combat criminal activity |
| theme_id | theme_name | description | significance | related_statutes | geographic_scope | temporal_aspects | stakeholders |
|---|---|---|---|---|---|---|---|
| 1334 | Unlicensed Money Transmitting Business | Liang Zhou operated an unlicensed money transmitting business that facilitated transfers between the U.S. and China, evading legal requirements. | Operating without a license undermines financial regulations and enables illicit activities. | 18 U.S.C. § 1960 | International | Recent development (ongoing investigation) | Law enforcement, Financial institutions, Customers |
| 1335 | Evasion of Anti-Money Laundering Laws | The operation circumvented U.S. anti-money laundering (AML) scrutiny by operating outside regulated financial systems. | Allowed illegal financial transactions to avoid detection, facilitating crimes like gambling and money laundering. | 18 U.S.C. § 1960 | International | Law enforcement, Financial regulators, Criminal enterprises | |
| 1336 | Capital Flight Controls Evasion | Helped Chinese customers bypass China's capital flight controls by converting yuan to USD for use in U.S. casinos. | Undermined China's economic policies and enabled unauthorized currency conversion. | International | Chinese authorities, Customers, Underground financial operators | ||
| 1337 | Asset Forfeiture | Zhou agreed to forfeit $446,330 as part of the plea agreement, representing proceeds from the illegal business. | Serves as a deterrent and recovers illicit funds from criminal activities. | 18 U.S.C. § 1960 (penalties section) | National (U.S.) | U.S. Government, Defendant | |
| 1338 | Threat to International Banking System | Underground financial institutions pose a danger to the international banking system by evading regulatory oversight. | Compromises the integrity of financial systems and hinders law enforcement's ability to detect criminal activity. | 18 U.S.C. § 1960 | International | International financial institutions, Law enforcement agencies | |
| 1339 | Gambling Funding | Customers used the illicitly obtained USD to gamble at Las Vegas casinos, bypassing China's capital controls. | Facilitates illegal gambling activities and circumvents financial regulations. | International | Casinos, Gamblers, Financial operators |
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