UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.

UNITED STATES OF AMERICA,

Plaintiff,

v.

APPROXIMATELY $63,804.37 FROM BANK OF 

AMERICA ACCOUNT NUMBER 898101766484

SEIZED ON OR ABOUT JULY 21, 2021,

APPROXIMATELY $11,740 SEIZED FROM A 

RESIDENCE IN BOCA RATON, FLORIDA, ON 

OR ABOUT JULY 21, 2021, and

APPROXIMATELY $99,980 SEIZED ON OR 

ABOUT JULY 22, 2021.

Defendants In Rem.

/

VERIFIED COMPLAINT FOR FORFEITURE IN REM

Plaintiff, the United States of America (the “United States”), by and through its 

undersigned counsel, brings this complaint and alleges as follows in accordance with Supplemental 

Rule G(2) of the Federal Rules of Civil Procedure: 

NATURE OF THE ACTION

1. This is a Verified Complaint for Forfeiture in rem, pursuant to 18 U.S.C. § 

981(a)(1)(A) and the procedures set forth in Rule G of the Supplemental Rules for Admiralty or 

Maritime Claims and Asset Forfeiture Actions, the Federal Rules of Civil Procedure, to forfeit 

seized U.S. currency and funds, more fully described as:

(i) All funds previously on deposit in Bank of America account number 

898101766484 (“BoA account”), approximately $63,804.37 seized on or about 

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July 21, 2021;

(ii) Approximately $11,740 in U.S. currency seized from a residence in Boca Raton, 

Florida, on or about July 21, 2021; and

(iii) Approximately $99,980 in U.S. currency seized on or about July 22, 2021.

(Collectively, the “Defendant Assets”).

JURISDICTION AND VENUE

2. This Court has jurisdiction over this subject matter. See 28 U.S.C. §§ 1345,

1355(a); 18 U.S.C. § 981(a)(1).

3. This Court has in rem jurisdiction over the Defendant Assets. See 28 U.S.C. §§ 

1345, 1355(a).

4. Venue for this action is proper in this District because acts or omissions giving rise 

to the forfeiture occurred in the Southern District of Florida, and because this is the same District 

where the Defendant currency was seized, and where the related seizure warrant was sought. See

28 U.S.C. § 1355(b)(1), 1395; 18 U.S.C. § 981(h). 

FACTUAL ALLEGATIONS 

5. Individual 1 and his/her spouse, Individual 2, are Brazilian citizens residing in Boca 

Raton, Florida (the “Residence”).

6. Individual 1 and Individual 2 opened and controlled bank accounts in their name 

and in the name of their companies, Company 1 and Company 2 (the “Companies”). 

7. The following accounts were held by Individual 1, Individual 2, or the Companies: 

i. Individual 1 – TD Bank account;

ii. Individual 2 – TD Bank account;

iii. Company 2 – TD Bank account;

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iv. Company 2– JP Morgan Chase account;

v. Company 1 – JP Morgan Chase account; and

vi. Company 1 –BoA account. 

8. Company 1 was incorporated in the State of Florida in or around July 2019, until 

its administrative closure in September 2022. Individual 1 and Individual 2 were the listed 

corporate officers for Company 1. In this complaint, all dates, times, and amounts are approximate 

unless stated otherwise.

9. Company 1’s address was the Residence.

10. Company 1 was created to provide catering services, according to the Florida 

Division of Corporations’ database. 

11. Company 1’s BoA account identified the Residence as the mailing address. 

12. Individual 1 is the sole signatory for Company 1’s BoA account.

13. Company 2 was incorporated in the State of Florida in or around December 2014.

Individual 1 and Individual 2 are the listed corporate officers for this business. 

14. Company 2’s address is the Residence.

15. Neither the State of Florida nor federal authorities have records of Individual 1, 

Individual 2, Company 1, or Company 2 registered as money transmitting businesses. 

16. Transaction activity in the Companies’ accounts, including Company 1’s BoA 

account, was inconsistent with legitimate business. Outgoing transaction activity was inconsistent 

with actual business operations as such activity did not include payroll, any obvious business 

expenses, or ongoing overhead. 

17. Bank records show deposits into the Companies’ accounts, including Company 1’s 

BoA account, made by unknown individuals at ATMs in various locations out of state, many on 

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the same day.

18. From approximately May 2018 to March 2021, the accounts held by Individual 1, 

Individual 2, and the Companies received over $13.3 million in cash deposits: 

CASH INFLOWS TO CORTEZ ACCOUNTS

Account Name Total Received Date Range

Individual 1 – TD Bank $1,253,167 05/2018 to 04/2019

Individual 2– TD Bank $128,640 09/2018 to 04/2019

Company 2 – TD Bank $1,473,084 09/2018 to 04/2019

Company 2 – JPMC $222,652 07/2019 to 05/2020

Company 1 - JPMC $4,301,258 09/2019 to 05/2020

Company 1 – B of A $5,979,208 09/2019 to 03/2021

Total $13,358,009

19. From approximately February 2021 to July 2021, law enforcement officials 

conducted surveillance at the Residence. Surveillance did not observe a catering business or other 

legitimate business activity occurring at the Residence. Neither Individual 1 nor Individual 2 were 

observed going to an office or other workplace.

20. Individual 1 frequently left the Residence to go to banks. Bank records include 

video images of Individual 1 making deposits at various ATMs and banks in South Florida. Law 

enforcement observed Individual 1 depositing cash at various ATMs. 

21. Company 1’s BoA account received substantial cash deposits each month and made 

substantial outgoing transfers. Between the approximate dates of September 4, 2019, and March 

31, 2021, Company 1’s BoA account:

i. Received $7,709,030 in deposits; 

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ii. Received $5,117,584.64 in ATM cash deposits;

iii. Received $2,052,867.14 in counter deposits; 

iv. Received daily or near daily deposits; and 

v. Cash deposits averaged $14,000. 

22. Between the approximate dates of September 4, 2019, and March 31, 2021, 

Company 1’s BoA account:

i. Debited $7,641,464; 

ii. Of that total amount, $6,766,614 was transferred to other business entities;

iii. Of that total amount, $1,977,546 was wired out in international wires; 

iv. Of that total amount, $3,670,960 was wired out; and

v. Debits averaged $6,000. 

23. A Bank of America financial representative confirmed to law enforcement that 

from April 2021 through July 2021, Company 1’s BoA account continued to receive substantial 

cash deposits and make significant outgoing transfers. 

24. On July 21, 2021, law enforcement executed a federal search warrant in case 21-

MJ-8281 for the Residence finding probable cause for violations of money laundering under 18 

U.S.C. § 1956 and unlicensed money transmission under 18 U.S.C. § 1960. 

25. Pursuant to that search warrant, law enforcement seized the Defendant $11,740 in 

U.S. currency from the Residence. 

26. One bundled stack of cash was located inside a black backpack with a Company 1

checkbook and mail addressed to Company 1.

27. The remaining bundled stacks of cash were in a speaker box located inside a dresser 

drawer in Individual 1’s closet. They were bundles of $20 and $100 bills, rubber banded, topped 

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with a sticky note with calculations.

28. On July 21, 2021, law enforcement executed a federal seizure warrant in case 21-

MJ-8282, for the BoA account in the name of Company 1 finding probable cause of violations of 

money laundering under 18 U.S.C. § 1956 and unlicensed money transmission under 18 U.S.C. § 

1960. 

29. Pursuant to that seizure warrant, Bank of America disbursed the contents of 

Company 1’s BoA account in a cashier’s check for $63,804.37.

30. On or about July 14, 2021, law enforcement observed Individual 3 deliver a box of 

purported currency to the Residence. 

31. On or about July 21, 2021, Individual 1 received an offer for additional U.S. 

currency from Individual 3 via WhatsApp. 

32. On or about July 22, 2021, Individual 3 met with Individual 1 in the driveway of 

the Residence. Individual 3 handed to Individual 1 a purple diaper box. Individual 3 said he/she

would send Individual 1 instructions through WhatsApp, and left.

33. The purple diaper box contained the Defendant $99,980 in U.S. currency in bundled 

$20 bills wrapped in rubber bands. 

34. The Defendant $99,980 in U.S. currency was seized by law enforcement on July 

22, 2021. 

35. Individual 1 had been performing foreign currency exchanges and money 

transmitting without a license in the U.S. or Brazil, individually and through use of his/her

businesses Company 1 and Company 2, since approximately September 2019.

36. Individual 1 transferred U.S. currency in the United States for funds in Brazil, and 

the converse, including but not limited to:

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i. Receiving U.S. currency and making payments in Brazil;

ii. Distributing U.S. currency to other people in the United States and directing them 

to make payments in Brazil;

iii. Receiving checks from accounts controlled by others; and

iv. Paying himself/herself a profit based on the currency exchange rate. 

37. Company 1 began as a catering business, but Individual 1 used it to buy and sell 

U.S. currency. 

38. Individual 1 met Individual 3 in a WhatsApp group for Brazilian immigrants in the 

United States. Individual 1 inquired how to send money to himself/herself in Brazil. Individual 1

gave Individual 3 $500 in U.S. currency and Individual 3 arranged for the equivalent to be paid to 

Individual 1 in Brazil. The two began to work together.

39. Individual 1 transmitted money both domestically and abroad. Some money was

sent to U.S. based bank accounts. Some money was sent within Brazil. Payments in Brazil were 

made using Brazilian bank accounts.

40. Individual 1 received instructions by phone calls and WhatsApp messages on where 

to send money after receiving U.S. currency. 

41. Individual 1 provided ATM cards to a co-conspirator in New Jersey, who had 

people deposit cash. 

42. Individual 1 deposited cash and checks for money transmitting into Company 1’s

BoA account. 

43. Individual 1 had at least a half-dozen customers who would deposit U.S. currency 

for funds in Brazil, or vice-versa. Individual 1 accepted customers at an office in Boca Raton, 

Florida, where Individual 3 had rented office space from another business. On approximately five 

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occasions, Individual 1 would sit with a counting machine and people would bring cash, each

between approximately $70,000 to $300,000. Individual 1 would confirm to Individual 3 the 

amount given. Individual 3 would send confirmation of crypto currency transactions. 

BASIS FOR FORFEITURE

44. Pursuant to 18 U.S.C. § 981(a)(1)(A), “[a]ny property, real or personal, involved in 

a transaction or attempted transaction in violation of section 1956, 1957, or 1960 of this title, or 

any property traceable to such property” is subject to forfeiture. 

45. Title 18, United States Code, Section 1960 prohibits the operation of unlicensed 

money transmitting businesses, which are defined as a money transmitting business that:

(A) is operated without an appropriate money transmitting license in a State 

where such operation is punishable as a misdemeanor or a felony under State law, 

whether or not the defendant knew that the operation was required to be licensed or 

that the operation was so punishable;

(B) fails to comply with the money transmitting business registration 

requirements under section 5330 of title 31, United States Code, or regulations 

prescribed under such section; or

(C) otherwise involves the transportation, or transmission of funds that are 

known to the defendant to have been derived from a criminal offense or are 

intended to be used to promote or support unlawful activity.

46. In the State of Florida, it is a felony criminal offense to operate a money 

transmitting business without a license. § 560.204, Fla. Stat.

47. Pursuant to 31 U.S.C. § 5330 and the regulations prescribed thereunder, a money 

transmitting business must be registered with the Secretary of the Treasury and an agent of a money 

transmitting business can be treated as a money transmitting business.

CLAIM

Property Involved in Unlicensed Money Transmitter Business Transaction

(18 U.S.C. § 981(a)(1)(A))

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48. The factual allegations in paragraphs 1 through 43 are re-alleged and incorporated 

by reference herein.

49. As set forth above, the Defendant Assets are involved in a transaction or attempted 

transaction in violation of 18 U.S.C. § 1960, or are property traceable to such property. 

50. Accordingly, the Defendant Assets are subject to forfeiture pursuant to 18 U.S.C. 

§ 981(a)(l)(A).

WHEREFORE, Plaintiff, the United States of America, requests that this Honorable 

Court issue warrants for the arrest of the Defendant Assets; that notice of this action be provided 

to persons known or thought to have an interest in or right against the Defendant Assets; that the 

Defendant Assets be forfeited and condemned to the United States of America; and for such other 

and further relief as this Court may deem just, necessary and proper.

Respectfully submitted,

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY

By: s/G. Raemy Charest-Turken

Gabrielle Raemy Charest-Turken (Fla. Bar # 15939)

Assistant United States Attorney

E-mail: Gabrielle.Charest-Turken@usdoj.gov

99 N.E. 4th Street, Suite 700

Miami, Florida 33132

Phone: (305) 961-9365

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