Case 3:22-mj-01145-BJM Document 1 Filed 09/14/22 Page 1 of 1

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
District of Puerto Rico

United States of America )

V. )
) Case No. 22-1145 (M)
)
ANGEL DE LA ROSA-JIMENEZ )
)
)
Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of October 2021 through the present in the county of San Juan in the
District of Puerto Rico & elsewhere , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 1028A Aggravated identity theft
18 U.S.C. § 1029(a)(5) Access device fraud
18 U.S.C. § 1957 Money laundering
18 u.s.c. § 371 Conspiracy

This criminal complaint is based on these facts:

See attached affidavit.
Reviewed by AUSA A. Alum.

The United States requests temporary detention pursuant to 18 U.S.C. §

3142(f)(2)(A) in light of the defendant's foreign ties, assumption of others'
identities to obtain currency, and access to U.S. currency.
,d Continued on the attached sheet.

Sworn in accordance with the requirements of Fed.

R.Crim. P. 4.1 by telephone at 8:20 a.m. this 14th
FBI SA Cristine Perez
day of September, 2022.
Printed name and title

Digitally signed by Hon.

Bruce J. McGiverin

Judge's signature

City and state: San Juan, Puerto Rico Bruce J. McGiverin , U.S. M .J.
Printed name and title

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AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT

I, Cristine Perez, being a duly sworn Special Agent with Federal Bureau of Investigation (FBI),
hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a law enforcement officer of the United States within the meaning of 18 U.S.C. §

2510(7), in that I am empowered by law to conduct investigations and to make arrests in

connection with federal felony and misdemeanor offenses. I am a Special Agent (SA) of the

FBI and have been employed as such since May 12, 2019. I am currently assigned to the

White Collar Crime squad in the San Juan, Puerto Rico Field Office of the FBI, where I

investigate financial crimes related to violations of Title 18 of the United States Code and

other violations of federal law. I have received the information contained in this affidavit

either through personal investigation or by discussions with other law enforcement

personnel.

2. I have twelve years of experience with the FBI of which nine were as an intelligence analyst

and three as a special agent. As an intelligence analyst, I gained basic investigation skills and

management of legal matters concerning fourth amendment searches, drafting affidavits,

domestic and international criminal enterprises, cyber threats/vulnerabilities, Confidential

Human Source (CHS) handling, evidence handing/collection, working with classified

intelligence/methods, basic intelligence analysis, and introduction to advanced investigative

techniques (pen registers, undercover operations, Title III wire intercepts, among others.).

This affidavit is intended to show merely that there is sufficient probable cause for the

requested warrant and does not set forth all of my knowledge about this matter.
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3. I have prepared this affidavit for the purpose of establishing probable cause to believe that

Angel De La Rosa-Jimenez has committed violations of 18 U.S.C. §§ 1028A (aggravated

identity theft); 1029(a)(5) (access device fraud); 1957 (money laundering); and 371

(conspiracy). The facts stated herein are based on my personal participation in this

investigation, my training and experience, and my conversations with other law enforcement

officers and persons with first hand knowledge.

FACTS ESTABLISHING PROBABLE CAUSE

A. Summary of the scheme

4. The FBI and the United States Postal Inspection Service have been investigating a fraudulent

scheme whereby the debit cards of mostly elderly clients of Banco Popular have been

fraudulently used to obtain money orders. Specifically, between in or about May 2022

through the present, Angel De la Rosa (also known as “Julio Zapata”) and others, posing as

either federal agents or bank officials have visited the residences of those they have

victimized claiming that their bank accounts had been compromised. Under the guise of

helping their victims restore the integrity of their respective accounts, De la Rosa asked

the victims to provide their ATM debit cards and pin numbers. Upon obtaining

physical possession of the debit cards, De la Rosa—aiding and abetting others, and aided

and abetted by others—would purchase Postal Money Orders at various U.S. Post Offices

throughout Puerto Rico. The Postal Money Orders would then be negotiated into cash

at U.S. Post Offices at a later time.

B. Events of August 9, 2022 result in Postal Inspectors identifying some of the

participants in the scheme

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5. On August 9, 2022, while conducting surveillance operations at the Plaza Las Americas

Finance Station and the General Post Office (GPO), located at 585 Franklin Delano

Roosevelt Avenue, San Juan, Puerto Rico, Postal Inspectors observed two individuals

attempting to purchase Postal Money Orders. Postal Inspectors approached these individuals

and asked if anyone had accompanied them to the GPO. They indicated that their friend

(hereafter Individual A) had accompanied them, and was waiting for them in the parking

lot outside the GPO. Individual A subsequently entered the GPO, after which

point the three voluntarily agreed to accompany the Postal Inspectors to the USPIS

Postal Police Office. Law enforcement agents later confirmed that Individual A had

cashed approximately 36 Postal Money Orders for approximately $1,000.00 each, and

conducted a consensual search of his vehicle. During the search, Postal Inspectors found

and seized approximately 17 Postal Money Orders, the total value of which was $16,750

(each Postal Money Order was worth between $850 and $1,000). Postal Inspectors

subsequently conducted a consensual search of Individual A’s residence, where they

found and seized Postal Money Order receipts and $11,750 in U.S. currency. Individual

A acknowledged that all the cash seized constituted fruits of money order transactions.

6. The next day, on August 10, 2022, Angel De la Rosa accompanied Individual A to the GPO,

and requested to speak to Postal Inspectors in connection with the money seized the day

prior. Even though De la Rosa was never placed under custody or under arrest, Postal

Inspectors advised him of his constitutional rights, which he voluntarily waived. While

speaking to Postal Inspectors, De la Rosa stated that he wanted to corroborate that law

enforcement seized money from Individual A and indicated that a portion of that seized

money belonged to him. Specifically, De la Rosa claimed that the money represented

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proceeds from sales of a jewelry business that he operates with others out of a location in

San Juan, Puerto Rico, which law enforcement agents identified as a structure located on

Borinquen Avenue in San Juan, Puerto Rico.

7. Additionally, De la Rosa also stated that in the past he has driven another person to several

Post Offices to make “the route” for purchasing and cashing money orders.

8. During his visit to the GPO, De la Rosa voluntarily provided two cellular phones to Postal

Inspectors and consented to their search. While searching De la Rosa’s phones, Postal

Inspectors found the following, among other things: photographs of debit cards issued to

Banco Popular customers that Postal Inspectors have confirmed were fraudulently used to

purchase Postal Money Orders; photographs of large amounts of U.S. currency; recordings

of De la Rosa speaking to bank customers, falsely claiming that their bank account

information had been compromised; a recording of De la Rosa discussing aspects of the

fraud scheme with other individuals; and records of cash purchases of over $40,000 worth of

jewelry from stores in New York. Images of receipts memorializing purchases on July 28,

2022 and August 8, 2022 are below:

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9. Law enforcement officers have confirmed that between May 2022 and the present,

approximately $350,000 worth of Postal Money Orders have been purchased using debit

cards that were reported to have been fraudulently obtained from bank customers.

Additionally, Postal Inspectors’ review of social media websites suggests that jewelry sales

from the location on Borinquen Avenue began in or about July 2022, as that is when the jewelry

business appears to have begun advertising online. According to records that Postal

Inspectors have reviewed from the Departamento de Hacienda (i.e., the Puerto Rico Tax

Authority), this jewelry business has no legal authorization to operate as a business in Puerto

Rico. Additionally, local tax records confirm that De la Rosa reported earnings of between

$10,000 and $12,000 in the last fiscal year, and that the individuals with whom De la Rosa

operates the jewelry business reported earnings of less than $12,000 in the last fiscal year. For

these reasons, I respectfully submit that there is a reasonable likelihood that the jewelry

described in the receipts pictured above constitute fruits of the fraudulent scheme and is being

used to launder ill-gotten proceeds from the fraudulent purchases of Postal Money Orders.

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10. On August 26, 2022, law enforcement officers conducted surveillance of the jewelry store on

Borinquen Avenue, and observed De la Rosa entering and remaining there.

C. Execution of a Federal Search Warrant at the Jewelry Store on Borinquen

Avenue

11. On September 9, 2022 U.S. Magistrate Judge Camille Vélez-Rivé issued a federal warrant

authorizing the search of the jewelry store on Borinquen Avenue. On September 13, 2022,

FBI agents and U.S. Postal Inspectors executed this search warrant, and seized jewelry;

approximately $16,000 in U.S. currency; and receipts of monetary remittances to the

Dominican Republic.

12. While law enforcement agents were executing the search warrant at the jewelry store, other

federal agents established surveillance outside of a residence in Carolina, Puerto Rico which

they believed to be occupied by De la Rosa. During the course of their surveillance, agents

observed De la Rosa and another individual enter a grey Mercedes Benz with dark tinted

windows. Carolina Municipal Police officers performed a traffic stop, as the tints on the

windows were not in compliance with Puerto Rico law. During the course of the stop, De la

Rosa opened a fanny pack to retrieve his identification at the request of the Municipal Police

officers; when De la Rosa opened his fanny pack, the Municipal Police officers observed a

large amount of U.S. currency. A photographic image of the fanny pack with U.S. currency

is below:

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Postal Inspectors arrived at the scene of the traffic stop shortly thereafter, and interacted

with De la Rosa the individual accompanying him. De la Rosa voluntarily provided written

consent to search WKH vehicle. During the search, the Postal Inspectors found D EXOOHW LQ WKH

JORYH FRPSDUWPHQW DQG the following, among the other items: (1) an approximate total

amount of $6,000 in U.S. currency [i.e. the money in the fanny pack] packaged similarly

to the currency seized from the jewelry store; (2) a receipt—located inside the fanny pack

along with the money—memorializing the purchase of a Miami Bracelet in New York

on August 23, 2022 for $8,572; (3) a Banco Popular debit card issued to a person

whose initials are W.A.C. belonging neither to De la Rosa Qor the individual

accompanying him; and (4) a Banco Popular business card issued to an “assistant branch

manager.” A photographic image of items two, three, and four are below:

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13. De la Rosa confirmed to Postal Inspectors that a bracelet he was wearing was that described

in the receipt seized from inside the fanny pack. According to De la Rosa, he purchased the

bracelet with his own money, but failed to specify how he earned that money. De la Rosa

further claimed that he inherited the money seized from the vehicle from his father who

allegedly died one year ago.

14. Law enforcement agents have confirmed that De la Rosa is a citizen of the Dominican

Republic, and a permanent legal resident of the United States.

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15. Based on my training and experience, I know that criminal organizations use various

techniques to launder illegally obtained currency. I know that one of the most common

means of laundering money is to convert illegally obtained currency into seemingly

legitimate financial instruments, such as money orders. I know that money orders can be

purchased from many institutions; however, the largest issuers in the United States are

Western Union, Money Gram, and the U. S. Postal Service.

16. Based on my training and experience, I know that the conversion of illicit currency into

money orders or similar financial instruments enables criminal organizations to place illegal

proceeds into a nation’s financial infrastructure without the inherent stigma and controls

associated with cash. These bearer instruments are then negotiated in the course of daily

commerce, thereby enabling criminal organizations to integrate illegally obtained funds into

the economy and create the appearance of legitimacy.

INTENTIONALLY LEFT BLANK

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CONCLUSION

17. Based on the facts set forth above, I respectfully submit that there exists probable cause to

charge Angel De la Rosa-Jimenez with violations of 18 U.S.C. §§ 1028A (aggravated

identity theft); 1029(a)(5) (access device fraud); 1957 (money laundering); and 371

lkrQ�
(conspiracy).

Special Agent Cristine Perez

Federal Bureau of Investigation

Sworn in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone at 8:20 a.m.
on September 14, 2022.

Digitally signed by Hon.

Bruce J. McGiverin

Bruce J. McGiverin
United States Magistrate Judge

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