Case 3:18-cr-00247-HZ Document 1 Filed 05/22/18 Page 1 of 5

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

UNITED STATES OF AMERICA 3:1i:r18 CR- 247-HZ

v. INFORMATION

WEN BING SHIEH, 18 U.S.C. § 1956(a)(l)(B)(ii) and (h)

Defendant.

THE UNITED STATES ALLEGES:

INTRODUCTORY ALLEGATIONS

I. Beauty Plus Global, also doing business as City Color, is a wholesale business

located in Ontario, California, engaged in the sale of cosmetics.

2. Defendant is the Chief Executive Officer Beauty Plus Global.

3. At all times relevant to the allegations in the Information, Beauty Plus Global was

not registered or otherwise licensed as·a money transmitting business either with the State of

California or the U.S. Department of Treasury Financial Crimes Enforcement Network and was

not exempt from licensing.

4. The money laundering scheme known as the Black Market Peso Exchange

("BMPE"), also known as Trade Based Money Laundering, is a common method used by drug

trafficking organizations ("DTOs") in Mexico to obtain pesos in exchange for U.S. dollars

("USDs") obtained from narcotics sales in the U.S.

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5. Mexican DTOs often use the BMPE to avoid the Mexican anti-money laundering

regulations adopted in 2010 that limit the amount of physical cash deposits in U.S. dollars that

Mexican financial institutions may receive.

6. BMPE schemes involve two otherwise unrelated problems faced by two different

groups. The first group involves Mexican DTOs who, as specified above, have too much U.S.

currency to transport to Mexico undetected. The second group is Mexican businesses--often

resellers-that need USDs (rather than Mexican pesos) to pay for product purchased from U.S.

suppliers, manufactures, and wholesalers. A peso broker arranges the sale of the DTO's illicit

USDs to Mexican businesses.

7. BMPE schemes typically operates as follows: first, a Mexican DTO contacts a

peso broker in Mexico who has a relationship with a Mexican business described above. The

peso broker facilitates the sale of the DTO's drug proceeds in the form ofUSDs located in the

U.S. to the Mexican business for Mexican pesos located in Mexico. Once the Mexican DTO

informs the peso broker where the bulk U.S. cash is located, the peso broker arranges for the

transportation of the illicit cash-either physically through a courier or through U.S. dollar

deposits of narcotics proceeds in the U.S.-to a U.S. wholesaler from which the Mexican

business has purchased product and to which the Mexican business owes USDs. The U.S.

wholesaler accepts the bulk U.S. currency or the cash deposits as payment from the Mexican

business and ships the goods to the Mexican business. The Mexican business, using the peso

broker as an intermediary, delivers the agreed upon amount of pesos to the Mexican DTO as

payment for the DTO's illicit USDs. The peso broker receives a commission for negotiating the

deal.

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8. In practice, a BMPE scheme typically involves numerous brokers and

intermediaries. For instance, one individual may have a relationship with DTOs and/or their

criminal associates who collect illicit USD proceeds throughout the U.S.; another individual may

have a relationship with Mexican businesses who need USDs to purchase U.S. goods; and a third

individual may have a relationship with Mexican DTOs and be responsible for delivering the

pesos to them in Mexico.

9. Ultimately, Mexican businesses purchase U.S. goods at exchange rates more

favorable than those offered through legitimate commercial channels, and Mexican DTOs

receive profits in the form of pesos from drug trafficking that appear to be legitimate proceeds

from international trade and do so without physically transporting the proceeds into Mexico.

COUNTl
(Conspiracy to Commit the Laundering of Monetary Instruments)
(18 U.S.C. § 1956(a)(l)(B)(ii) and (h))

Beginning on or about January 1, 2013 and continuing until November 5, 2015, within

the District of Oregon, the Western District of Washington, the Central District of California,

and elsewhere, WEN BING SHIEH, defendant herein, did knowingly agree with other persons,

known and unknown to the government, to conduct financial transactions affecting interstate and

foreign commerce, which defendant knew, or deliberately avoided learning the truth, were

proceeds of a specified unlawful activity, which were designed in whole or in part to avoid a

transaction reporting requirement under State or Federal law.

MANNER AND MEANS OF THE CONSPIRACY

To carry out that conspiracy, defendant SHIEH, and other named and unnamed co-

conspirators did, among other acts, the following:

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a. SHIEH allowed out-of-state cash deposits into a Bank of America account in the

name of Beauty Plus Global, from unknown depositors, including identified drug

traffickers in Oregon, without obtaining identification or ascertaining the identity of

the person making the cash deposits;

b. SHIEH opened the Bank of America account and had signing authority for the bank

account;

c. SHIEH and other employees at Beauty Plus Global allowed bulk cash payments

exceeding $10,000, without obtaining identification or ascertaining the identity of the

individuals making the payments;

d. SHIEH and other employees at Beauty Plus Global failed to determine why the

payments were being made in cash, other than being told it was to secure a better

exchange rate;

e. SHIEH held bulk cash payments in a safe in his office and then divided the amounts

so they could be deposited in dollar amounts less than $10,000 each;

f. SHIEH made multiple cash deposits into the Beauty Plus Global bank accounts of

Bank of America and Bank of the West in round-dollar amounts under $10,000 that

were designed to avoid a transaction reporting requirement under state or federal law;

g. SHIEH participated in counting bulk cash payments at Beauty Plus Global and

personally observed that the payments were made in a mix of new and old bills of

varying denominations;

h. SHIEH and Beauty Plus Global employees failed to investigate the nature, source,

ownership and control of the of the cash deposits in the Bank of America account and

the bulk cash payments received by Beauty Plus Global;

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i. SHIEH and Beauty Plus Global employees agreed to customer requests to provide

discounted shipping invoices that did not truly reflect the value of the orders shipped.

All in violation of Title 18 United States Code, Section 1956(a)(l)(B)(ii) and (h).

DATED: May 22, 2018. Respectfully submitted,

BILLY J. WILLIAMS
United States Attorney

STEVEN T. MYGRANT, OSB #031293

Assistant United States Attorney

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