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Owners of Underground, International Financial Institutions Sentenced for Operating Unlicensed Money Transmitting Business

2021-06-03 · Press release

Mentions 1960 Verified 1960

Assistant U.S. Attorneys Daniel Silva (619) 546-9713 and Mark W. Pletcher (619) 546-9714

NEWS RELEASE SUMMARY – June 3, 2021

SAN DIEGO ­–Lei Zhang of Las Vegas, Nevada, was sentenced in federal court yesterday to 15 months in prison and the forfeiture of $150,000 for operating an unlicensed money transmitting business.

Zhang is believed to be the first individual in the United States sentenced for his role in developing a new form of unlawful underground financial institution that transfers 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 set forth in court documents, Zhang would collect U.S. dollars (in cash) from various third-parties in the United States and deliver that cash to a customer, typically a high-roller gambler from China who could not readily access cash in the United States due to capital controls that limit to $50,000 per year the amount of Chinese currency an individual can convert to foreign currency. Upon receipt of the U.S. dollars, the gambler would transfer the equivalent value of Chinese yuan (using a banking app) from the customer’s Chinese bank account to a Chinese bank account designated by defendant Zhang. For facilitating these transactions, Zhang was paid a commission based on the monetary value illegally transferred. 

Zhang further admitted that he was regularly introduced to customers by casino hosts, who sought to increase the gambling play of the casino’s customers.  By connecting cash-starved gamblers in the United States with Zhang’s illicit money transmitting businesses, the casinos increased the domestic cash play of their China-based high-roller customers.  All a gambler needed was a mobile device with remote access to a China-based bank account.  As a result, Zhang managed to transmit and convert electronic funds in China into hard currency in the United States, all while circumventing the obstacles imposed both by China’s capital controls and the anti-money laundering scrutiny imposed on all United States financial institutions. For their efforts, the casino hosts often received a cut of Zhang’s commission.  

“The groundbreaking work by these investigative agents in identifying and ferreting out this new form of illicit money transmittal cannot be overstated,” noted Acting U.S. Attorney Randy Grossman.  “Prosecuting global money laundering is a priority for the U.S. Attorney’s Office.”

Special Agents from Homeland Security Investigations, IRS Criminal Investigation Las Vegas Financial Crimes Task Force, and the Drug Enforcement Administration led the investigation into Zhang’s operations.  

DEFENDANT                                               Case Number 20-CR-370-WQH                             

Lei Zhang                                                        Las Vegas, NV             Age: 41

SUMMARY OF CHARGES

Operation of Unlicensed Money Transmitting Business – Title 18, U.S.C., Section 1960

Maximum penalty: Five years in prison and $250,000 fine

AGENCIES

Homeland Security Investigations

IRS Criminal Investigation Las Vegas Financial Crimes Task Force

Drug Enforcement Administration

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https://www.justice.gov/usao-sdca/pr/owners-underground-international-financial-institutions-sentenced-operating-unlicensed
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participant_id name role title organization location age nationality status
1906 Daniel Silva Assistant U.S. Attorney Assistant U.S. Attorney U.S. Attorney's Office San Diego, California
1907 Mark W. Pletcher Assistant U.S. Attorney Assistant U.S. Attorney U.S. Attorney's Office San Diego, California
1908 Lei Zhang defendant Las Vegas, Nevada 41 sentenced
1909 Randy Grossman Acting U.S. Attorney Acting U.S. Attorney U.S. Attorney's Office San Diego, California
agency_id agency_name abbreviation role office_location agents_mentioned contribution
1192 Homeland Security Investigations investigation led the investigation into Zhang’s operations
1193 IRS Criminal Investigation Las Vegas Financial Crimes Task Force investigation Las Vegas led the investigation into Zhang’s operations
1194 Drug Enforcement Administration DEA investigation led the investigation into Zhang’s operations
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
986 Operation of Unlicensed Money Transmitting Business 18 U.S.C. § 1960 Five years in prison $250,000 Lei Zhang sentenced 1 enrichment 2026-09-16T19:45:57+00:00
2916 operating an unlicensed money transmitting business 1 press 2026-09-16T19:45:57+00:00
2917 unlicensed money transmitting business 1 press 2026-09-16T19:45:57+00:00
2918 Unlicensed Money Transmitting Business – Title 18, U 1 press 2026-09-16T19:45:57+00:00
fin_id action_type amount currency description asset_type defendant status
373 forfeiture $150,000 USD cash cash Lei Zhang ordered
victim_id victim_type description number_affected loss_amount geographic_scope vulnerability_factors impact_description
257 government US and Chinese governments international (US and China) Circumvention of anti-money laundering laws and capital controls
258 financial institution US financial institutions United States Undermined regulatory oversight through illicit money transmission
quote_id quote_text speaker_name speaker_title speaker_organization quote_type context significance
1145 The groundbreaking work by these investigative agents in identifying and ferreting out this new form of illicit money transmittal cannot be overstated. Randy Grossman Acting U.S. Attorney U.S. Attorney’s Office statement Commenting on the investigation into Zhang’s operations Highlights the significance of the investigation and prosecution of global money laundering
theme_id theme_name description significance related_statutes geographic_scope temporal_aspects stakeholders
1251 Unlicensed Money Transmitting Business Operating an unlicensed business that transferred money between the U.S. and China by collecting cash in the U.S. and facilitating equivalent yuan transfers in China via banking apps. Central to the charges under 18 U.S.C. § 1960, enabling evasion of U.S. anti-money laundering laws and Chinese capital controls. 18 U.S.C. § 1960 International Recent development (first such case in the U.S.) Lei Zhang, Law enforcement, Financial institutions, Casinos, High-roller gamblers
1252 Money Laundering The scheme circumvented U.S. anti-money laundering scrutiny and Chinese capital flight controls by disguising the source of funds through cross-border transfers. Key aspect of the case's prosecution, highlighting evasion of financial regulations. 18 U.S.C. § 1960 International Recent development Law enforcement, Financial regulators, High-roller gamblers
1253 International Cooperation The case involved actions affecting both U.S. and Chinese laws, requiring collaboration between U.S. law enforcement and potentially foreign authorities. Highlights the need for cross-border coordination to combat financial crimes that span jurisdictions. International U.S. law enforcement, Chinese authorities (implied)
1254 Casino Involvement Casino hosts referred high-roller gamblers to Zhang's service to increase gambling activity, receiving a commission from Zhang. Demonstrates how casinos may facilitate illegal financial activities to boost business. National (U.S.) Recent development (as part of the scheme's operation) Casinos, Casino hosts, High-roller gamblers, Law enforcement
1255 Capital Controls Evasion The scheme allowed Chinese gamblers to bypass China's $50,000 annual currency conversion limit by using Zhang's services. Undermined China's financial policies and enabled illicit fund transfers. International Historical trend (response to existing Chinese capital controls) Chinese gamblers, Lei Zhang, Chinese financial authorities
1256 Technology Facilitation Use of mobile banking apps to transfer funds remotely between China and the U.S., enabling the scheme's operation. Highlights modern methods of conducting illegal financial transactions through technology. International Recent development (as technology enables such cross-border transfers) Banking app providers, High-roller gamblers, Lei Zhang

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