According to the indictment, beginning in February 2008, and continuing through May 2012, Raul Mendoza (Mendoza) and Isidro Noe Mendoza-Ortiz (Mendoza-Ortiz), conspired with each other and others to structure currency (the depositing of just under $10,000) by depositing transactions with the intent to evade the reporting requirements as required by law. Daily cash receipts from the business, Chopeque Auto Sales, which is owned by Mendoza, were received at the business and structured into separate accounts at various banks to avoid the $10,000 reporting requirements. From February 26, 2008 through May 29, 2012, they structured over 700 deposit totaling $4,543,714.
As part of the conspiracy, on June 4, 2011, Mendoza, Mendoza-Ortiz and Julia Castillo-Caraveo (Castillo-Caraveo), knowingly caused Chopeque Auto Sales, a non-financial trade or business, to fail to file a Federal IRS Form 8300, a report required by law for all currency transactions over $10,000 received by a business. Particularly, they sold a 2004 Dodge Ram 1500 in exchange for $10,500 that was represented by undercover law enforcement officers to be the proceeds of a specified unlawful activity (drug distribution) and that they did so with the intent to conceal the nature of the proceeds of the specified unlawful activity and to avoid IRS Form 8300 reporting requirements. On March 8, 2012, Mendoza and Castillo-Caraveo followed a similar pattern and sold a 2008 Chevrolet Silverado 1500 in exchange for $20,900 that was represented by undercover law enforcement officers to be the proceeds of a specified unlawful activity (drug distribution); no IRS From 8300 was filed.
The defendants conspired to conceal the nature and source of the specified unlawful activity and attempted to launder drug proceeds. Particularly, Chopeque Auto Sales sold automobiles to known drug dealers, prepared false documents relating to the sale of vehicles to known drug dealers, structured currency deposits to conceal the source, falsely claimed to law enforcement authorities to be a valid lien holder of a seized vehicle in order to assist a known drug dealer in seeking the return of the vehicle. Upon conviction of the offenses above, they shall forfeit to the United States all of the defendants right, title and interest in all property, real or personal, involved in such offenses, or all proceeds traceable to such property, for which the defendants are joint and severally liable.
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