Joumaa

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IN THE UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIA

UNITED STATES OF AMERICA

AYMAN JOUMAA,also known as "Junior,"

Defendant .

Alexandr ia Division

(UNDER SEAL )

CRIMINAL NO. l : l l -CR-560

Count 1

Count 2

Forfeiture

INDICTMENT

21 U.S.C. 959(a), 960,963(Conspiracy to Distribute FiveKilograms or More ofCocaineKnowing and Intending that itwill be Unlawfully Importedinto the United States)18 U.S.C. 1956(h)(Conspiracy to Commit MoneyLaundering)18 USC 853, 970(Criminal Forfeiture)

NOVEMBER 2011 TERM - at Alexandria, VirginiaTHE GRAND JURY CHARGES THAT:

BackgroundAt al l t imes relevant to this Indictment:

1. On or about January 26,2011, the United States Department of the Treasury'sOffice ofForeignAsset Control (OFAC) designated the defendant, along with other individuals

and entities, as SpeciallyDesignated Narcotics Traffickers pursuant to the Foreign NarcoticsKingpin Designation Act.

2. This designation by OFAC was based on, among other things, the defendant'scoordination of the transportation, distribution, and sale ofmulti-ton shipments of cocaine from

Case 1:11-cr-00560-TSE Document 1 Filed 11/23/11 Page 1 of 7 PageID# 1

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SouthAmerica andthe laundering of hundreds of millions of dollarsof proceeds from the saleofcocaine in Europeand the Middle East.

3. The defendant's coordination ofmoney laundering activitiesoccurred in theUnited States,Lebanon,Benin, Panama, Colombia, the DemocraticofCongo, and elsewhere.

4. LosZetasMexican drugcartelis a violentdrugtrafficking organization thatcontrols drug smuggling corridors from Mexico totheUnited States, often through massacreattacks, including the 2011 massacre at theMonterey Casino inNuevo Leon, Mexico.

5. Colombia is responsible for the production of 90%of the cocaine that is importedinto the United States. The cocaine that leaves Colombia is sent along the Central Americancorridor to Guatemala,Honduras, andMexico, for eventual shipment to the United States.

6. The launderingofdrug related proceeds is a critical step in a conspiracytodistribute cocaine for unlawful importation into theUnited States. The laundering of drugproceeds allows foreign drug traffickers to remain undetected so that they can continue todistribute cocaine andotherdrugs for importation intotheUnited States. The laundered drugproceeds that are returned to the drug traffickers inColombia and other countries allow the drugtrafficking conspiracy to continue by funding further drug production anddistribution aimed atimporting future drugshipments to theUnited States.


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COUNT 1

(Conspiracy to Distribute FiveKilograms or More of Cocaine Knowing and Intending thatitwould be Unlawfully Imported into the United States)

THE GRAND JURY FURTHER CHARGES THAT:From in or about 2004 and continuing thereafter up to and including the date of the filing

of this Indictment, the exact dates being unknownto the GrandJury, in Colombia,Lebanon,Panama, and elsewhere, the defendant, AYMAN JOUMAA, also known as "Junior," and othersknown andunknown to theGrand Jury, did knowinglyand intentionally combine, conspire,confederate, andagtee to committhe following offense against the UnitedStates: to knowinglyand intentionally distribute fivekilograms or more of a mixtureandsubstance containing adetectable amount of cocaine, a Schedule II controlled substance, knowing and intending thatsuch substance would be unlawfully imported into the United States, in violation ofTitle 21,United States Code, Section 959(a).

Theallegations in paragraphs 1 through 6 of this Indictment are incorporated herein byreference.

Manners and Means of the ConspiracyThe defendant and his co-conspirators used the following manners and means, among

others, in furtherance of the conspiracy:7. It was partof the conspiracy that thedefendantand his co-conspirators

coordinated the shipmentof at least tens of thousands ofkilograms of cocaine fromColombia,throughCentral America and Mexico, to the UnitedStates, including but not limited to 85,000kilograms of cocaineshipped from Colombiaforsale to Los Zetas drug cartel fromin and around


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2005 through in and around 2007.

8. It was further a part of the conspiracythat the defendant and his co-conspiratorslaundered at least hundreds ofmillions ofdollars in proceeds of illegal drug sales in the UnitedStates and elsewhere, including but not limited to an amount in excess of$250million in drugrelated proceeds representing cocaine salesin the United States,Mexico, Central America, andEurope, whichthedefendant laundered from inand around 1997 through in and aroundSeptember 2010.

9. It was further a part of the conspiracy that the defendant and others, known andunknown to the grandjury, coordinatedthe shipmentofmulti-thousand kilogram quantitiesofcocaine from Colombia to Guatemala, Honduras, and Mexico for sale to Los Zetas drug cartel inMexico. The ultimate destination fo r this cocaine was the Uni ted States.

10. Itwas further part of the conspiracythat the defendant would arrange for thelaunderingof drug-relatedproceeds fromMexico, Europe (predominantly Spain), andWestAfrica to Colombia. The defendant's co-conspirators would contact the defendant via email,BlackberryPIN,or telephone in order to arrange for the delivery of drug related proceeds tomembers of the defendant's organization. The defendant and members ofhis organization wouldthen launder these proceeds and return them to the cocaine suppliers in Colombia. The defendantwould chargea fee of between 8% and 14%for the launderingof these proceeds. These drugproceeds received by the defendant andmembers of his organization were in the form of UnitedStates currency and represented proceeds from the sale of cocaine in the United States.

11. It was further part of the conspiracy that the defendant and his co-conspirators


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would receive bulk deliveries ofUnited States currency. These deliveries of bulk cash, whichrepresented proceeds of the sale of cocaine in theUnitedStates,weremade in Mexico City,Mexico. Once the drug proceedswere delivered to the defendant and his co-conspirators,thelaundered proceeds wouldbe paidout in Venezuela or Colombia. Payment inVenezuela wasinthe formofBolivars. Payment inColombiawas in the formofColombian pesos. The defendantwould launder these funds and make payment within 1 to 5 days from the date ofdelivery of theUnited States currencyinMexico. During the courseof the conspiracy, the defendant typicallypicked upbetween $2and4 million at a timein Mexico City.

12. It was furtherpart of the conspiracythat the defendant and his co-conspiratorswouldpick up drug-related proceeds in Mexico, Europe,and West Africa. Further, the defendantand his co-conspirators wouldpick up UnitedStatescurrencyin MexicoCity,Mexico. Thedefendantwould then launder these proceedsand repaythem to drug traffickers in ColombiaandVenezuela. The United States currency laundered by the defendant represented the proceeds ofthe sale of cocaine shipped fromColombiato Guatemala, Honduras, and Mexico, for sale to theLosZetas trafficking organization in Mexico. Theultimatedestinationof thecocaineshipped toLos Zetas drug cartel was the United States.(In violation of Title 21, United States Code, Section 963).


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COUNT2

(Conspiracy to Commit Money Laundering)

THE GRAND JURY FURTHER CHARGES THAT:From in or about 2004 and continuing thereafter up to and including the date of the filing

of this Indictment, in the United States, Colombia, Lebanon, Panama, and elsewhere, thedefendant, AYMAN JOUMAA, and others known and unknown to the Grand Jury, didknowinglyand intentionallycombine, conspire, confederate,and agree to conduct financialtransactionsinvolving the proceeds of a specified unlawfulactivity, to wit, the manufacture,importation, sale,anddistribution of a controlled substance, whichfinancial transactionsinvolving interstate and internationalcommercewere designed in whole and in part to concealand disguise the nature, location, source, ownership,and control of the proceedsof a specifiedunlawful activity, to wit, the manufacture, importation, sale, and distributionofa controlledsubstance, in violation ofTitle 18, United States Code, Section 1956(a)(l)(B)(I).

The allegations in paragraphs 1 through 12of this Indictment are incorporated herein byreference.

(In violation of Title 18,United States Code,Sections 1956(a)(l)(B)(i) and (h)).


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FORFEITURE NOT ICE

Thedefendant, if convictedof the violationalleged in Count 1of this Indictment, shallforfeit to the United Statespursuant to Title 21, United States Code, Section 853(a), any propertyconstituting, or derived from, anyproceeds eachdefendant obtained, directly or indirectly, astheresult of such violation; andanyof the defendant's propertyused, or intended to be used, in anymanner orpart, to commit, orto facilitate thecommission of,suchviolation. Thispropertyincludes, but is not limited to $850,000,000 in UnitedStatescurrency, representing proceeds thatthe defendant obtained in the course of the conspiracy alleged in Count 1 of this Indictment.

If convicted of themoneylaundering conspiracy chargedin Count 2 of this Indictment,the defendant shall forfeitto theUnitedStates, pursuantto Title 18,UnitedStatesCode, Section982(a)(1), any property, real orpersonal, involved in such offense, orany property traceable tosuch property, including but not limited to$850,000,000 inUnited States currency, representingproceeds that the defendant obtained in the course of the conspiracy alleged inCount 2of thisIndictment.

(Pursuant toTitle 21, United States Code, Section 853 and Title 18, United States Code, Section982(a)(1)).

A TRUE BILLPssfiw* to the r-Govctfnmqnt&t,theoriginal of this page hashscnfile#ireicr seal w ti e Clerks GOfcc .

By:

Neil H. MacBrideUnited States Attorney

Michael P. Ben'AryAssistant United States Attorney

Foreperson


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