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Operator of Underground, International Financial Institution Pleads Guilty to Operating Unlicensed Money Transmitting Business

2020-10-08 · Press release

Mentions 1960 Verified 1960
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
extras_json
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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