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INDICTMENT
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EXTRACTED KEY WORDS
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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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