According to the indictment, from March 31, 2011 through May 1, 2012, Hills allegedly engaged in financial transactions, which transactions involved the proceeds of specified unlawful activity, that is, the distribution of controlled substances. The indictment further states that the defendant allegedly conducted financial transactions while knowing that the property involved in each transaction represented the proceeds of some form of unlawful activity.
Furthermore, Hills did knowingly and willfully make a false statement or report for the purpose of influencing the action of JP Morgan Chase, a federally insured financial institution, in connection with a vehicle loan application. Lastly, beginning on or about April 15, 2012, and continuing through on or about January 29, 2013, Hills knowingly and willfully failed to file an income tax return and pay income tax due and owing to the United States for the calendar year 2011.
Upon conviction of the violations alleged in the indictment Hills shall forfeit to the United States, any and all of the defendants’ right, title and interest in all property, real or personal, involved in such offenses, or all property traceable to such property, including but not limited to the following: 2008 Ducati motorcycle, and U.S. currency located in a Roth IRA.
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