Case 3:13-cr-00205-SRU Document 1 Filed 10/31/13 Page 1 of 7

UNITED STATESDISTRICTCOURT
DISTRICTOF CONNECTICUT
H-13-1
LINITEDSTATESOF AMERICA

CRIMINAL NO.

v.

J,i'l' ) eq frl/c-

VIOLATIONS:

THANOUSONEVOLARAT,a.k.a."Pitt,"
PHONEPHITHACK
VOLARAT,a.k.a.ooTone,"
SOMPATANACHANMINARAJ,a.k.a.
"Johnny,"and
RONALD KHAMVONGSAY

(Conspiracy
to
l8 U.S.C.$ 1956(h)
CommitMoneyLaundering)
to Distribute
2l U.S.C.$ 846(Conspiracy
andto Possess
with Intentto Distribute
Marijuana)
in Monetary
l8 U.S.C.$ 1957(Engaging
Transactions
in CriminallyDerived
Property)
( Money
l8 U.S.C.$ l9s6( aXlXAXi)
Laundering)
l8 U.S.C.$ 2 (AidingandAbetting)
21U.S.C.$ 853andl8 U.S.C.$ 982( aXl )
(CriminalForfeiture)

INDICTMENT
The GrandJury charges:

COLINTONE
(Conspiracyto Commit Money Laundering)
L

-J]

From approximatelyJanuary 2009 through approximately September2011, the

exact datesbeing unknown to the Grand Jury, in the District of Connecticutand elsewhere,the
THANOUSONE VOLARAT. A.K.A."Pitt.'' PHONEPHITHACK VOLARAT. A.K.A.
dEf-CNdANtS
"Tone," SOMPATANA CHANMINARAJ, a.k.a."Johnny,o'and RONALD KHAMVONGSAY,
and others known and unknown to the Grand Jury, did knowingly combine, conspire and agree

Case 3:13-cr-00205-SRU Document 1 Filed 10/31/13 Page 2 of 7

with eachotherandwith otherpersonsknownandunknownto theGrandJuryto commitoffenses

againsttheUnitedStates
in violationof Title I 8, UnitedStates
Code,Section1956,to wit:
a.

to knowingly conduct and attempt to conduct financial transactions

affecting interstateand foreign commerce,which transactionsinvolved the proceedsof a specified

unlawful activity, that is, a conspiracy to distribute and to possesswith intent to distribute
marijuana,with the intent to promotethe carrying on of the specifiedunlawful activity, and that
while conductingand attemptingto conduct such financial transactionsknew that the property
involved in the financialtransactionsrepresentedthe proceedsof someform of unlawful activity,
in violationof Title 18,United StatesCode,Section1956(aXlXA)(i);and
b.

to knowingly conduct and attempt to conduct financial transactions

affecting interstatecommerceand fbreign commerce?which transactionsinvolved the proceedsof

a specified unlawful activity, that is, a conspiracyto distribute and to possesswith intent to
distribute marijuana,knowing that the transactionswere designedin whole or in part to conceal
and disguisethe nature,location, source,ownershipand control of the proceedsof the specified
unlawful activity, and that while conductingand attemptingto conductsuchfinancialtransactions,
knew that the property involved in the financial transactionsrepresentedthe proceedsof some
fbrm of unlawful activity,in violationof Title 18,United StatesCode,Section1956(a)(lXBXi).
Manner and Means
2.

The manner and means used to accomplish the objectives of the conspiracy

included,amongothers,the following:
a.

In order to facilitate and promotethe operationof the narcoticstrafficking

businessand to concealthe source,ownershipand locationof the cashproceeds,a co-conspirator

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depositedcash proceedsderived from narcoticstrafficking activity at locations in Connecticut,

which proceedswere then transferredvia interstatewires to locationsin Oregonand California.
b.

In order to facilitate and promotethe operationof the narcoticstrafficking

businessand to concealthe source,ownershipand locationof the cashproceeds,a co-conspirator

deposited cash proceeds derived from narcotics trafficking activity at bank branches in
Connecticut,which proceedswere then withdrawn from bank branchesin Oregonand California.
c.

In order to facilitate and promotethe operationof the narcoticstrafficking

businessand to concealthe source,ownershipand locationofthe cashproceeds,a co-conspirator

depositedcashproceedsderivedfrom narcoticstrafficking activity at casinosin Connecticut.
All in violationof Title 18,United StatesCode,Section1956(h).
COTINT TWO
(Conspiracyto Distribute and to Possesswith Intent to Distribute Marijuana)
3.

From approximatelyJanuary 2009 through approximately September201l, the

exact datesbeing unknown to the Grand Jury, in the District of Connecticutand elsewhere,the
defendantRONALD KHAMVONGSAY, and others known and unknown to the Grand Jury,
including THANOUSONE VOLARAT, a.k.a. "Pitt," PHONEPHITHACK VOLARAT, a.k.a.
"Tone," and SOMPATANA CHANMINARAJ, a.k.a."Johnny," who are not namedas defendants
in this Count but are chargedwith a violation of Title 21, United StatesCode, Section 846 in
separateIndictments,did knowingly and intentionallyconspireto violate the narcoticslaws of the
United States.
4.

It was a part and an object of the conspiracythat KHAMVONGSAY, and others

known and unknown to the Grand Jury, would distribute and possesswith intent to distribute a
controlledsubstance,
in violationof Title 21, United StatesCode,Section8al(aXl).

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5.

The controlled substanceinvolved in the offense was a mixture and substance

containinga detectableamount of marijuana,a ScheduleI controlledsubstance,in violation of

Title 21, UnitedStatesCode,Section841(bXlXD).
All in violationof Title 21, United StatesCode,Section846.
COLINTSTHREE TROUGH FIVE
(Engagingin MonetaryTransactionsin Criminally Derived Property)
6.

On or about the dates set forth below. in the District of Connecticut and

elsewhere,the defendantSOMPATANA CHANMINARAJ, a.k.a. "Johnny," did knowingly

engage,and attempt to engage,in monetarytransactionsin criminally derived property, to wit:
United Statescurrency, by, through or to a financial institution affecting interstateor foreign
commerce,and such monetarytransactionswere of a value greaterthan $10,000,such property
having been derived from a specifiedunlawful activity, that is, a conspiracyto distributeand to
possesswith intent to distributemarijuana:

MONETARYTRANSACTION

COLINT

DATE

April 16,2010

Depositof $26,000into a JPMorganChaseaccountendingin

2876.

April 19,2070

Depositof $35,700into a JPMorganChaseaccountending in

2876.

April 20,2010

Depositof $20,000into a JPMorganChaseaccountending in

2876.

All in violationof Title 18,United StatesCode,Sections1957and2.

COLINTSSIX TROUGH EIGHT
(Money Laundering)
7.

On or about the dates set tbrth below, in the District of Connecticut and

elsewhere,the def-endantRONALD KHAMVONGSAY did knowingly conduct and attemptto

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conduct financial transactionsaffecting interstate and foreign commerce, which transactions

involved the proceedsof a specifiedunlawful activity, that is, a conspiracyto distribute and to
possesswith intent to distribute marijuana,with the intent to promote the carrying on of the
specifiedunlawful activity, and that while conductingand attemptingto conduct such financial
transactionsknew that the propertyinvolved in the financial transactionsrepresentedthe proceeds
of someform of unlawful activitv:

COUNT

DATE

MONETARYTRANSACTION

June 17,2011

Depositof $9,000 into a Bank of America accountending in

5481.

July1,2011

Depositof $9,900into a Bank of Americaaccountendingin

2617.

July 1,2011

Depositof $9,900into a Bank of Americaaccountendingin

9753.

All in violationof Title 18,United StatesCode,Sections1956(a)(1XA)(i)and2.

FORFEITUREALLEGATION
(Money LaunderingOffenses)
8.

lJpon conviction of one or more of the money laundering ofTensesalleged in

Counts One and Three through Eight of this Indictment, the defendants THANOUSONE
SOMPATANA
VOLARAT, A.K.A.O'Pitt,"PHONEPHITHACK VOLARAT, A.K.A.OOTONC,"
CHANMINARAJ, a.k.a."Johnny,"and RONALD KHAMVONGSAY shall forfeit to the United
States,pursuantto Title 18, United StatesCode,Section982(aXl), all right, title, and interestin
any and all money and otherproperty,real or personal,involved in suchoffenses,and any property
traceableto suchproperty.

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9.

If any of the above-describedforfeitable property, as a result of any act or

omission of a defendant, cannot be located upon the exercise of due diligence, has been
transferred,sold to, or depositedwith a third party, has beenplacedbeyondthejurisdiction of the
court, has been substantiallydiminished in value, or has been commingled with other property
which cannotbe divided without difficulty, it is the intent of the United States,pursuantto Title
21, United StatesCode,Section853(p),as incorporatedby Title 18,United StatesCode,Section
982(bxl) and Title 28, {.JnitedStatesCode, Section 2461(c),to seek forfeitureof any other
propertyof said defbndantup to the value of the forfeitablepropertydescribedabove,
All in accordance
with Title 18,United StatesCode,Section982(aXl), and Rule 32.2(a),
FederalRules of Criminal Procedure.
FORFEITUREALLEGATION
(ControlledSubstanceOffense)
10.

lJpon convictionof the controlledsubstance

offenseallegedin Count Two of this

Indictment.the defbndantRONALD KHAMVONGSAY shall forfeit to the United States.

pursuanttoTitle 21, United StatesCode,Section853,all right, title, and interestin any property
constituting of, or derived from, proceedsobtained, directly or indirectly, as a result of the
violation of Title 21, United StatesCode, Sections846, and any property used,or intendedto be
used,in any manneror part,to commit,or to facilitatethe commissionof the saidviolation,anda
sum of money equalto the total amountof proceedsobtainedas a result of the offense.

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lL

If any of the above-described

forfeitable property, as a result of any act or

omission of a defendant,cannot be located upon the exerciseof due diligence,has been

transferred,
soldto, or depositedwith a third party,hasbeenplacedbeyondthejurisdictionof the
court,hasbeensubstantiallydiminishedin value,or hasbeencommingledwith otherproperty
that cannotbe dividedwithout difficulty, it is the intentof the United States,pursuantto Title 21,
UnitedStatesCode,Section853(p),to seekforfeitureof any otherpropertyof saiddefendantup
to the valueof the forfeitablepropertydescribedabove.
All in accordance
with Title 21, United StatesCode,Section853, and Rule 32.2(a),
FederalRulesof CriminalProcedure.
A TRUEBILL
',t

LINITEDSTATESOF AMERICA
I

tM.
. Fr^r,.-h.r r,. i

DEIRDREM. DALY
ACTINGTINITEDSTATESATTORNEY

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, ,;rl1fh0forgoing

tola/[iy'
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ASSISTANTTINITEDSTATESATTORNEY

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