ma cr Paid. SEALED 2014 ae PH 2: ‘ UNITED STATES DISTRICT COURT ®Y-—;, WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION UNITED STATES OF AMERICA, Plaintiff, INDICTMENT SA14cRO338 HG [Vio 18- U.S.C, § 1349, 343-Wire Fraud Conspir 18 U.S.C. §§ 371, 2314- Conspiracy to Transport or Cause to be Transported Stolen Property 18 U.S.C. § 1956(h)(a)(2)(A) , (a)(2)(B) - Money Laundering Conspiracy. ] v. ROLANDO R. GONZALEZ-TREVINO, Defendant. THE GRAND JURY CHARGES: COUNT ONE (18 U.S.C. §§ 1349, 1343) ‘That beginning on or about December 2005, and continuing up to and including the date of this indictment, in the Westem District of Texas, the Defendant, ROLANDO R. GONZALEZ-TREVINO conspired, combined, confederated and agreed with others known and unknown to the Grand Jury, to commit offenses against the United States, that is, the Defendants conspired, combined,confederated, and agreed with others to commit wire fraud, a violation of Title 18, United States Code, Section 1343, that is the Defendants conspired to devise a scheme to defraud and to obtain money and property by means of materially false and fraudulent pretenses, representations and promises and for the purpose of executing said scheme and attempting to execute said scheme, caused to be transmitted by means of wire communication in interstate and foreign commerce, writings, signs, signals, pictures and sounds, all in violation of Title 18, United States Code, Sections 1349 and 1343. COUNT TWO (18 U.S.C. §§ 371, 2314) ‘That beginning on or about December 2005, and continuing up to and including the date of this indictment, in the Westen District of Texas, the Defendant, ROLANDO R. GONZALEZ-TREVINO: conspired, combined, confederated and agreed with others known and unknown to the Grand Jury, to commit offenses against the United States, that is, the Defendants conspired, combined, confederated, and agreed with others to unlawfully transport, transmit, transfer, and cause to be transported, transmitted, and transferred in interstate and foreign commerce from the Republic of Mexico to the United States securities and money of the value of $5,000 or more, knowing the same to have been stolen, converted, and taken by fraud, in violation of Title 18, United States Code, Sections 371 and 2314. Overt Acts In furtherance of the conspiracy and to carry out the objects of their conspiracy, the Defendant, along with others known and unknown to the Grand Jury, committed and caused thecommission of the following overt acts within the Western District of Texas: 1. On or about January or February of 2006, Co-Conspirator One (CC1) directed Co-Conspirator Two (CC2), an employee of the Mexican State of Coahuila, to pay Co-Conspirator Three (CC3) a large amount of Mexican pesos. fom the treasury of the State Government of Coahuila. 2. Onor about February of 2006, CCI called a meeting of multiple co-conspirators and instructed officials of the state government of Coahuila to pay 100 million pesos to CC3. 3. Onor about February, 2006, CCI advised CC2 that CC1 planned to purchase media outlets for himself and others from various media entities operating within the state of ‘Coahuila, 4. Onorabout January 24, 2009, CCI, CC2, and Co-Conspirator Five (CCS) and others traveled, via private aircraft, from Coahuila, Mexico to San Antonio, Texas, to meet with ccs. 5. Onor about January 25, 2009, CC1, CC2, Co-Conspirator Four (CCA), and CCS met with ROLANDO R. GONZALEZ-TREVINO at the Sonterra Golf Club, located at Sonterra and Stone Oak Parkway in San Antonio, Texas. At this meeting, CCI inquired about the status of payments that were to be made to the Defendant, ROLANDO R, GONZALEZ-TREVINO and advised that the Defendant would provide two (2) invoices to support these payments. CCI advised that the amount to be paid would be 25 million Mexican Pesos 6. Onor about March 2009, and anterior to the trip to San Antonio, C2 attended a meeting at the Governor's Mansion in Saltillo, Coahuila, Mexico with CCS and Co-Conspirator Six (CC6), who worked for C2. CCI provided CC2 and CC6 bank account number(s) forROLANDO R. GONZALEZ-TREVINO at First National Bank in Edinburg, Texas and directed CC2 and CC6 to make two payments to the account(s) in the amounts of 15 million pesos and 10 million pesos. CCI instructed CC2 to make the two payments to ROLANDO R. GONZALEZ-TREVINO on April 7, 2009 and May 4, 2009. 7. Onor about April 7, 2009, CC2 and CC6 caused an electronic bank wire transfer to be made to ROLANDO R. GONZALEZ-TREVINO’s account in First National Bank (FNB) of Edinburg, Texas. ‘The money was transferred from Mexico through an account held by Administrativos Diam Ante SC and later through an account from Banco Mercantil Del Norte (BANORTE) into the Edinburg account in the United States. The amount of the wire transfer ‘was $1,100,513.57 USD. 8. Onor about May 7, 2009, CC2 and CC6 caused three (3) wire transfers in the amount of $162,758.65, $294,740.08, and $288,769.94 to be transmitted from Construcciones Chavana De CV to ROLANDO R. GONZALEZ-TREVINO’s account in First National Bank of Edinburg, Texas, the account number *#****281. This account was the same FNB Edinburg account that was used in the April 7, 2009 wire transfer. These wire transfers were not completed because First National Bank of Edinburg closed the account, 9. Onor about May 7, 2009, ROLANDO R. GONZALEZ-TREVINO telephoned CCI, who in turn instructed CC2 to contact ROLANDO R. GONZALEZ-TREVINO regarding ‘the attempted transfer. CC2 made the call and ROLANDO R. GONZALEZ-TREVINO. advised CC2 that there was a problem with the wire transfer. ROLANDO R. GONZALEZ-TREVINO asked CC2 to call the bank to complete the transfer. 10. On or about May 8, 2009, CC2 and CC6 caused the payment of 10,000,000Mexican Pesos to be made to ROLANDO R. GONZALEZ-TREVINO, Bank records revealed that three (3) wire transfers in the amount of $162,758.65, $294,740.08, and $288,769.94 were completed on May 8, 2009 from Construeciones Chavana De CV. The aggregate amount of these transfers is $746,268.67. This transaction was completed by wire transfer from the Bank of ‘New York Mellon to the International Bank of Commerce (IBC)- Laredo. The wire was deposited into account number 6002364676 in the name of Rolando R. GONZALEZ-Trevino, All in violation of Title 18, United States Code, Sections 371 and 2314. COUNT THREE (18 U.S.C. §§ 1956(h), (a)(2)(B)) ‘That beginning on or December 2005, and continuing unt ig on or about the date of this indictment, in the Western District of Texas, and elsewhere, Defendant, ROLANDO R. GONZALEZ-TREVINO , knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed others to the Grand Jury known and unknown, to commit offenses against the United States, that is, the Defendant and others conspired, combined, confederated and agreed among themselves and with each other to conduct and attempt to conduct financial transactions, to-wit: 1) knowing the monetary instrument and funds involved in the transportation, transmission and transfer represent the proceeds of some form of unlawful activity and knowing that such transportation, transmission and transfer is designed in whole or in part to conceal and disguise the nature, location, source, ownership and control of the proceeds of specified unlawful activity, in violation of Title 18, United States Code, Section 1956(a)(2)(B), and (2) knowingly engages inand attempts to engage in a monetary transaction in criminally derived property of a value greater than $10,000 and is derived from specified unlawful activity, in violation of Title 18, United States Code, Section 1957, all in violation of Title 18, United States Code, Sections 1956 (h), and (a)(2\(B), NOTICE OF UNITED STATES OF AMERICA'S DEMAND FOR FORFEITURE, [See Fed. R. Crim. P. 32.2] COUNTS ONE and TWO Conspiracy/Wire Fraud Violations and Forfeiture Statutes [Title 18 U.S.C. § 1349; subject to forfeiture pursuant to Title 18 U.S.C. § 981 (a)(1)(C) made applicable to criminal forfeiture by Title 28 U.S.C. § 2461] Conspiraey/Transportation of Stolen Moneys/Securities Violations and Forfeiture Statutes [Title 18 U.S.C. §§ 371 and 2314; subject to forfeiture pursuant to Title 18 U.S.C. § 981 (@)(1)(C) made applicable to criminal forfeiture by Title 28 U.S.C. § 2461] COUNT THREE, Conspiracy to Launder Monetary Instruments Violations and Forfeiture Statutes [Title 18 U.S.C. § 1956(h); subject to forfeiture pursuant to Title 18 U.S.C. § 982(a)(I)] As a result of the foregoing criminal violations set forth in Counts One - Three, the United States of America gives notice to DEFENDANT ROLANDO R. GONZALEZ-TREVINO of its intent to seek the forfeiture of the below described property upon conviction and pursuant to Fed, R. Crim. P. 32.2, Title 18 U.S.C. § 981 (a)(1)(C) made applicable to criminal forfeiture by Title 28 US.C. § 2461, and Title 18 US.C. § 982(a)(2)(A),which state: Title 18 U.S.C. § 981(a)(1) The following property is subject to forfeiture to the United States:(© Any property, real or personal, which constitutes or is derived from proceeds traceable to . . . any offense constituting "specified unlawful activity” (as defined in section 1956(c)(7) of this title), or a conspiracy to commit such offense. ‘As made applicable by Title 28 U.S.C. § 2461. Title 18 U.S.C. § 982 (a)(1) The court, in imposing sentence on a person convicted of an offense in violation of section 1956, 1957, ... of this title, shall order that the person forfeit to the United States any property, real or personal, involved in such offense, or any property traceable to such property This Notice of Demand for Forfeiture includes, but is not limited to, the following: Money Judgment As a result of the foregoing criminal violations set forth in the above-described Counts, DEFENDANT ROLANDO R. GONZALI EZ-TREVINO shall forfeit to the United States all right, title and interest, pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, 1 18 U.S.C. § 981(@)(1)(C) made applicable to criminal forfeiture by Title 28 U.S.C. § 2461 and Title 18 U.S.C. § 982(a)(1), in the following described Money Judgment of Forfeiture: ‘A sum of money equal to One Million Eight Hundred Thousand Eight Hundred and NO/100 Dollars ($1,800,800.00), representing the amount of proceeds derived from or traceable to the violations set out in the above-described Counts and for which DEFENDANT ROLANDO R. GONZALEZ-TREVINO is liable. Substitute Assets Prov [Title 21 U.S.C. § $53(p) and Rule 32.2 of the Federal Rules of Criminal Procedure] If any of the money judgment described above as being subject to forfeiture for violations of Title 18 U.S.C. §§ 1349, 371 & 2314, and 1956(h), as a result of any act or omission of DEFENDANT ROLANDO R. GONZALEZ-TREVINO: (1) cannot be located upon the exercise of due diligence;(2) has been transferred or sold to, or deposited with, a third person; (3) has been placed beyond the jurisdiction of the Court; (4) has been substantially diminished in value; or (5) has been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, pursuant to Title 21 U.S.C. § 853(p), to seek forfeiture of any other property of said Defendant up to the value of the above for ible property. A TRUE BILL ‘OREPERSON OF THE GRAND JURY — ROBERT PITMAN UNITED STATES ATTORNEY, BY: pecs — RUSSELL D. LEACHMAN Assistant U.S. Attorney