IN THE UNITED STATES DISTRICT COURT

DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA : CRIMINAL NO.: 20-MJ-091

 :

v. : 

 :

ANGELO ZANELLI, :

 :

Defendant. : 

STATEMENT OF OFFENSE

Pursuant to Rule 11 of the Federal Rules of Criminal Procedure, defendant Angelo 

ZANELLI (hereinafter “defendant” or “ZANELLI”) and the United States agree and stipulate that 

at all relevant times:

1. ZANELLI is a national and citizen of Peru. He is also a lawful permanent resident 

of the United States.

2. From in or about October 19, 2018 through in or about October 26, 2018, 

ZANELLI unlawfully, willfully, and knowingly conspired with others to defraud the United States, 

and to export defense articles listed on the U.S. Munitions List (“USML”) from the United States 

to Bolivia without first obtaining a license or other written approval from the U.S. Department of 

State, Defense Directorate of Trade Controls (“DDTC”), in violation of 22 U.S.C. §§ 2778(b)(2), 

(c) and Title 22, Code of Federal Regulations, Sections 121.1, 123.1, and 127.1. The DDTC is 

located in the District of Columbia.

3. On October 19, 2018, ZANELLI met his co-conspirator at a house in Miami, 

Florida. The co-conspirator had flown to the United States from Bolivia. After the co-conspirator 

expressed an interest in buying firearms that he could illegally export to Bolivia, ZANELLI

accompanied his co-conspirator to a gun store located in Hialeah, Florida. The co-conspirator 

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selected the firearms he wanted and gave money to ZANELLI, which ZANELLI used to place a 

down payment of approximately $2,500 on seven pistols, in particular, model AK-47 Pistol 

Century Arms MICRO DRAGO (7.62x39), and 100 AK-47 magazines. ZANELLI also filled out 

the paper work that was required to purchase the firearms, using his name as the purchaser, even 

though he knew the firearms were being purchased for the co-conspirator.

4. On or about October 24, 2018, the co-conspirator, who then was in Bolivia, wired 

funds to ZANELLI in the amount of $961.54 USD. ZANELLI used those funds to purchase two 

large stereo speakers that he and the co-conspirator intended to use to hide the firearms they 

intended to illegally export to Bolivia.

5. On October 26, 2018, ZANELLI met with the co-conspirator again, and he and his 

co-conspirator went to the gun store, where they attempted to finalize their order. The gun store 

refused to finalize the purchase and would not sell the firearms to ZANELLI and the coconspirator.

6. The gun store employee provided ZANELLI and his co-conspirator with contact 

information for an individual who he indicated may be able to assist them, by selling them firearms 

in an illegal manner. Shortly thereafter, the co-conspirator and ZANELLI called that individ ual

using a cell phone. Unbeknownst to ZANELLI and the co-conspirator, the individual they had 

called was an undercover federal agent with Homeland Security Investigations (“undercover 

agent”). During the phone call, the co-conspirator agreed to meet with the undercover agent to 

purchase firearms.

7. On October 26, 2018, the co-conspirator met with the undercover agent to purchase 

firearms, but ZANELLI did not attend that meeting. 

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8. On October 29, 2018, ZANELLI met with federal agents and provided a 

consensual, non-custodial interview. During the interview, ZANELLI admitted that he knew the 

firearms he attempted to purchase at Miami Guns were going to be smuggled to Bolivia, and that 

it was illegal to do so. ZANELLI also said that the co-conspirator offered to pay him $150 USD 

for each AK-47 pistol that he purchased for the co-conspirator. ZANELLI also told the agents that 

the co-conspirator wired him $964 USD so that he could buy stereo speakers, which he did. 

ZANELLI said he took the speakers apart to see how many firearms could be hidden inside.

9. The seven (7) AK-47 Pistol Century Arms MICRO DRAGO (7.62x39) and 100 

AK-47 magazines were defense articles on the USML. Throughout the conspiracy, neither 

ZANELLI nor his co-conspirator had a license from the DDTC to legally export weapons from 

the United States to Bolivia. Furthermore, as stated above, ZANELLI knew that it was illegal to 

cause their exportation to Bolivia.

Respectfully submitted,

MICHAEL R. SHERWIN

ACTING UNITED STATES ATTORNEY

By: /s/ Frederick Yette

Frederick Yette, D.C. Bar 385391

Assistant United States Attorney

 555 4th Street, N.W.

Washington, D.C. 20530

(202) 252-7733

Frederick.Yette@usdoj.gov

DEFENDANT’S ACCEPTANCE

I have read this Statement of Offense and have discussed it with my attorney, Robert E. 

Abreu. I fully understand this proffer and I acknowledge its truthfulness, agree to it and accept it 

without reservation. I do this voluntarily and of my own free will. No threats have been made to 

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