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STEPHAN A. COLLINS
Assistant U.S. Attorney
Federal Building & U.S. Courthouse
222 West Seventh Avenue, #9, Room 253
Anchorage, Alaska 99513-7567
Phone: (907) 271-5071
Fax: (907) 271-1500
Email: Stephan.Collins@usdoj.gov
INDICTMENT
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Beginning at some exact time unknown to the grand jury but at least in or about May,
2016 and continuing to on or about September 6, 2016, within the District of Alaska and the
confederate and agree with each other and others known and unknown to the grand jury, to
§ 1956, to wit: to knowingly conduct financial transactions affecting interstate and foreign
commerce: the transfer of money between Alaska and California, which transactions
involved the proceeds of a specified unlawful activity, that is, the unlawful distribution of a
controlled substance, which is a violation of 21 U.S.C. § 841(a)(1), with the intent to promote
the carrying on of the unlawful distribution of controlled substances. While conducting such
financial transactions, the defendants knew that the property involved in the financial
transactions represented the proceeds of some form of unlawful activity, in violation of Title
18 U.S.C. § 1956(a)(1)(A) and knew the transactions were designed in whole or in part to
conceal and disguise the nature, location, source, ownership, and control of the proceeds of
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Case 3:19-cr-00067-RRB-DMS Document 2 Filed 06/20/19 Page 2 of 3
All of which is in violation of Title 18, United States Code, Section 1956(h).
A TRUE BILL.
s/ Stephan A. Collins
STEPHAN A. COLLINS
Assistant U.S. Attorney
United States of America
s/ Bryan Schroder
BRYAN SCHRODER
United States of America
United States Attorney
DATE: 06/19/2019
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Case 3:19-cr-00067-RRB-DMS Document 2 Filed 06/20/19 Page 3 of 3