United States Drug Enforcement Administration

FRESNO, Calif. - Raeb Chou, of Modesto, pleaded guilty today to one count of conspiracy to structure cash transactions and one count of structuring, and co-defendant Chantha A. Chim, of Murietta, pleaded guilty today to one count of structuring.
 
According to court documents, Chou, Chim and co-conspirators obtained prescriptions for oxycodone and hydrocodone from pharmacies in Modesto, and then transported and mailed the pills to Washington and other states for distribution on the black market. In addition, Chou and co-defendant Phally Thach opened bank accounts into which co-conspirators deposited the cash proceeds of the oxycodone and hydrocodone sales in amounts of $10,000 or less.

After receiving the cash deposits from co-conspirators, Chou and Chim withdrew the cash from those accounts in amounts of $10,000 or less to attempt to prevent Currency Transactions Reports from being filed by the banks on her cash deposits. Currency Transactions Reports are reports prepared by financial institutions for any transactions involving more than $10,000 in cash. These reports are filed with the Department of Treasury and are made available to law enforcement. Chou withdrew more than $120,000 cash proceeds of drug distribution from her bank accounts; Chim withdrew more than $70,000 cash proceeds of drug distribution from her bank accounts.

Both defendants are scheduled to be sentenced by Judge Anthony W. Ishii on May 5, 2014. Chou faces a maximum statutory penalty of five years in prison and a $250,000 fine for conspiracy and a maximum statutory penalty of 10 years in prison and a $500,000 fine for aggravated structuring. Chim faces a maximum statutory penalty of five years in prison and a $250,000 fine for structuring. The actual sentences, however, will be determined at the discretion of the court after consideration of any applicable statutory factors and the Federal Sentencing Guidelines, which take into account a number of variables.

This case is being brought as part of Operation Footprint, a nationwide law enforcement initiative led by the U.S. Attorney’s Offices, the Internal Revenue Service - Criminal Investigation, the Drug Enforcement Administration, and the United States Postal Inspection Service. Operation Footprint targets large drug trafficking organizations by identifying the transfer of drug proceeds through financial institutions, bulk cash smuggling and other forms of money transfers. Operation Footprint is focused on bringing criminal charges based on Bank Secrecy Act violations in addition to violations of the Controlled Substances Act and the Money Laundering Control Act. This case is also the product of the Organized Crime Drug Enforcement Task (OCDETF), a focused multi-agency, multijurisdictional task force investigating and prosecuting the most significant drug trafficking organizations throughout the United States by leveraging the combined expertise of federal, state and local law enforcement agencies.

This case is also the product of the Organized Crime Drug Enforcement Task (OCDETF), a focused multi-agency, multi-jurisdictional task force investigating and prosecuting the most significant drug trafficking organizations throughout the United States by leveraging the combined expertise of federal, state and local law enforcement agencies. Assistant U.S. Attorney Grant B. Rabenn is prosecuting the case.