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UNITED STATES v MOHAMED M HUSSEIN Click to find out why . . .



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CaseNo: USVMMH169654, Plaintiff: UNITED STATES, State: MA Massachusetts, UniqueCaseRef: LCD>USVMMH169654, , ContentID: 120250268

Case Documents
1 2000-08-07 INDICTMENT
[ see first page and extracted highlights below  ] ItemID: 124171
6 pages
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Total Documents: 1 document , 6 pages
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1 . INDICTMENT

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                               UNITED  STATES  DISTRICT  COURT
                                   DISTRICT  OF  MASSACHUSETTS



UNITED  STATES  OF  AMERICA                     )  CRIMINX  NO.
                  V.                            ,'
                                                 )     18           U.S.C.       §  1960
MOHAMED M.  HUSSEIN,                             )  (Operating                    an  Illegal      
LIBAN  M.  HUSSEIN,                              I                   Transmittal            
                                                 )  18  U.S.C.  §  982
                           Defendants.           )            (Criminal           Forfeiture)


                                                INDICTMENT
           The  Grand  Jury  charges  that  at  all  times  relevant                               
Indictment:
                                              INTRODUCTION
           1.  Defendants          Mohamed  M.  Hussein  and  Liban  M.  Hussein
operated        Barakaat  North  Americar  Inc.  ("BNA"  or  "Barakaat")
located  at  925  Washington  Street  #l,  Dorchester,                                        
Documents  filed             with  the  Massachusetts                          Secretary        of 
behalf       of  Barakaat  listed            Liban  M.  Hussein  as  the  President                
Barakaat  and  Mohamed  Hussein  as  the  Clerk  of  Barakaat.                                     
Articles        of  Organization            filed       for  Barakaat  state  that  the
purpose  of  the  corporation                  is  to  engage  in  the  business  of  "money
transfer        by  electronic         means."
           2.  Barakaat  accepted  funds  in  Dorchester,                                    
transmission             in  interstate        and  foreign                    commerce.         

                                                              1



portion            of  the  business  conducted  at  Barakaat  involved                            
transmittal             of  funds,  for  a  fee,  fram  Dorchester,                            
and  elsewhere             to  the  United  Arab  Emirares                       (`UAE").
            3.       Under  Massachusetts             law,  a  business  which  accepts
deposits            of  money  for  the  purpose  of  transmitting                             
foreign            countries       is  required       to  obtain  a  license                   
operation            of  a  foreign        money  transmittal                   business  from  the
Commonwealth  of  Massachusetts.                          Specifically,               it  is  a 
under  Massachusetts                 General  Laws  Chapter  169,  Section  16  to
operate  a  foreign                money  transmittal                business  without             
license.
            4.      on  or  about  August  7,  2000,  Liban  Hussein,  as  President               
Barakaat  North  America,  Inc,,  filed                              an  application            
Commonwealth  of  Massachusetts,                       Division            of  Bank  and  Loan 
("Division             of  Banks"),         to  obtain  a  License  to  Engage  in  the
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