Owners of Underground, International Financial Institutions Sentenced for Operating Unlicensed Money Transmitting Business
2021-06-03 · Press release
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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