UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
B-12-2
UNITED STATES OF AMERICA Criminal Number:
v. VIOLATIONS:
RALPH CROZIER 18 U.S.C. 1956(h) (Conspiracy to Launder
Monetary Instruments)
The Grand Jury charges:
18 U .S.C. 1956(a)(3)(B) (Attempt to
Launder Monetary Instruments)

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INDICTMENT
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(Conspiracy to Launder Monetary Instruments)
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1. From approximately October 20 10 through September 13,2011, the exact dates being
unknown to the Grand Jury, in the District of Connecticut and elsewhere, the defendant RALPH
CROZIER, together with others known and unknown to the Grand Jury, did knowingly combine,
conspire and agree with other persons known and unknown to knowingly conduct and attempt to
conduct one or more financial transactions affecting interstate and foreign commerce, which
transactions involved the proceeds of specified unlawful activity, that is, narcotics trafficking,
knowing that the transactions were designed in whole or in part to conceal and disguise the nature,
location, source, ownership and control of the proceeds of said specified unlawful activity, and that
while conducting and attempting to conduct such financial transactions, knew that the property
involved in the financial transactions represented the proceeds of some form of unlawful activity,
in violation ofTitle18, United States Code, Sections 1956(a)(1)(B)(i).
Case 3:13-cr-00113-AVC Document 12 Filed 06/11/13 Page 1 of 3
2. The manner and means used to accomplish the objectives of the conspiracy included,
among others: concealing the nature, location, source, ownership and control of narcotics trafficking
proceeds by converting said proceeds into an interest bearing corporate bond drawn on a company,
the identity of which is known to the Grand Jury.
All in violation of Title 18, United States Code, Section 1956(h).
COUNT TWO
(Attempt to Launder Monetary Instruments)
3. From approximately February 21,2013 through April 11 ,2013, the exact dates being
unknown to the Grand Jury, in the District of Connecticut and elsewhere, the defendant RALPH
CROZIER, with the intent to conceal and disguise the nature, location, source, ownership and control
of property believed to be the proceeds of a specified unlawful activity, that is, a conspiracy to
distribute and to possess with intent to distribute narcotics, did knowingly conduct and attempt to
conduct a financial transaction affecting interstate and foreign commerce, which transaction involved
property represented to be the proceeds of the specified unlawful activity.
In violation of Title 18, United States Code, Section 1956(a)(3)(B).
FORFEITURE ALLEGA nON UNDER 18 U.S.C. 982(a)
(Money Laundering)
4. Upon conviction of one or more of the money laundering offenses alleged in Counts
One and Two of this Indictment, the defendant RALPH CROZIER shall forfeit to the United States
of America pursuant to Title 18, United States Code, Section 982( a)(1), all right, title, and interest
in any and all money and other property involved in each offense in violation of Title 18, United
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Case 3:13-cr-00113-AVC Document 12 Filed 06/11/13 Page 2 of 3
States Code, Section 1956(h) and Title 18, United States Code, Section 1956( a)(3 )(B), and all
property traceable to such property, and a sum of money equal to the total amount of money involved
in each offense, or conspiracy to commit such offense, for which the defendant is convicted.
5. If any ofthe above-described forfeitable property, as a result of any act or omission
of the defendant, cannot be located upon the exercise of due diligence, has been transferred, sold to,
or deposited with a third party, has been placed beyond the jurisdiction of the court, has been
substantially diminished in value, or has been commingled with other property which cannot be
divided without difficulty, it is the intent of the United States, pursuant to Title 21, United States
Code, Section 853(p), as incorporated by Title 18, United States Code, Section 982(b), to seek
forfeiture of any other property of said defendant up to the value of the forfeitable property described
above.
All in accordance with Title 18, United States Code, Section 982(a)(I), and Rule 32.2(a),
Federal Rules of Criminal Procedure.
A TRUE BILL
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UNITED STATES OF AMERICA
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